PETITION TO LIST THE GIRAFFE (GIRAFFA CAMELOPARDALIS) UNDER THE ENDANGERED SPECIES ACT. April 19, 2017

Barbara Hollweg PETITION TO LIST THE GIRAFFE (GIRAFFA CAMELOPARDALIS) UNDER THE ENDANGERED SPECIES ACT April 19, 2017 by CENTER FOR BIOLOGICAL DIVERSITY, HUMANE SOCIETY INTERNATIONAL, THE HUMANE SOCIETY OF THE UNITED STATES, INTERNATIONAL FUND FOR ANIMAL WELFARE, and NATURAL RESOURCES DEFENSE COUNCIL

Notice of Petition Secretary Zinke U.S. Department of the Interior 1849 C Street NW Washington, D.C. 20240 exsec@ios.doi.gov Acting Director Jim Kurth U.S. Fish and Wildlife Service 1849 C Street NW Washington, D.C. 20240 Jim_Kurth@fws.gov Janine Van Norman, Chief Branch of Foreign Species, Endangered Species Program U.S. Fish and Wildlife Service 5275 Leesburg Pike, MS: ES Falls Church, VA 22041 Janine_Vannorman@fws.gov Petitioners The Center for Biological Diversity (Center) 378 N Main Avenue, Tucson, AZ 85701 The Center is a non-profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center is supported by more than one million members and activists throughout the United States. The Center and its members are concerned with the conservation of endangered species and the effective implementation of the Endangered Species Act. Humane Society International (HSI) 1255 23 rd St., NW Suite 450 Washington, DC 20037 Humane Society International is one of the only global animal protection organizations working to help all animals including animals in laboratories, animals on farms, companion animals and wildlife and our record of achievement demonstrates our dedication and effectiveness. HSI: Celebrating Animals, Confronting Cruelty. The Humane Society of the United States (HSUS) 1255 23 rd St., NW Suite 450 Washington, DC 20037

The Humane Society of the United States ( HSUS ) is the nation s largest animal protection organization. Based in Washington, DC, HSUS works to protect all animals and combat cruelty through litigation, legislation, investigation, education, advocacy, grant-making, emergency rescue missions, field work, and direct care to tens of thousands of animals. HSUS has worked for decades to improve the plight of African wildlife, including increasing Endangered Species Act ( ESA ) protection for imperiled species like elephants, lions, and chimpanzees. International Fund for Animal Welfare (IFAW) 290 Summer Street Yarmouth Port, MA 02675 Founded in 1969, IFAW rescues and protects animals around the world. With projects in more than 40 countries, IFAW rescues individual animals, works to prevent cruelty to animals, and advocates for the protection of wildlife and habitats. Natural Resources Defense Council (NRDC) 40 West 20th Street 11th floor New York, NY 10011 NRDC works to safeguard the earth its people, its plants and animals, and the natural systems on which all life depends. We combine the power of more than two million members and online activists with the expertise of some 500 scientists, lawyers, and policy advocates across the globe to ensure the rights of all people to the air, the water, and the wild. Authors: Mark Hofberg, IFAW; Tanya Sanerib, CBD; Masha Kalinina, HSI; Adam Peyman, HSI; Elly Pepper, NRDC; Sylvia Fallon, NRDC; Paul Todd, NRDC; Teresa M. Telecky, Ph.D., HSI; Anna Frostic, HSUS; Jeff Flocken, IFAW; Sarah Uhlemann, CBD; Shaye Wolf, CBD; Dipika Kadaba, CBD.

Submitted this 19th Day of April, 2017 Pursuant to Section 4(b) of the Endangered Species Act (ESA), 16 U.S.C. 1533(b); Section 553(e) of the Administrative Procedure Act (APA), 5 U.S.C. 553(e); and 50 C.F.R. 424.14(a), the Center for Biological Diversity, International Fund for Animal Welfare, Humane Society International, The Humane Society of the United States, and Natural Resources Defense Council hereby petition the Secretary of the Interior, through the U.S. Fish and Wildlife Service (Service), to protect the giraffe (Giraffa camelopardalis) as an endangered species under the Endangered Species Act, 16 U.S.C. 1533, or alternatively if taxonomic consensus changes or the Service decides to list an entity below the species level, we request that all giraffe subspecies or distinct population segments be protected at least as threatened, with qualified subspecies or distinct population segments protected as endangered. This Petition presents substantial scientific and commercial information indicating that the giraffe is in danger of extinction throughout all or a significant portion of its range. See 50 C.F.R. 424.14(h)(1) ( substantial scientific or commercial information refers to credible scientific or commercial information in support of the petition's claims such that a reasonable person conducting an impartial scientific review would conclude that the action proposed in the petition may be warranted). Therefore, the Secretary of the Interior, through the Service, must make an initial finding that the petitioned action may be warranted. 16 U.S.C. 1533(b)(3)(A)(emphasis added) (The Secretary must make this initial finding [t]o the maximum extent practicable, within 90 days after receiving the Petition ); HSUS v. Pritzker, 2014 WL 6946022 (D.D.C. 2014) (holding that conclusive evidence is not required to make a positive 90-day finding). The giraffe has suffered a major reduction in population size across its range primarily due to habitat loss, commercial overutilization, and severe poaching, and such decline continues unabated. The Service has a duty to protect the iconic giraffe by listing the species as endangered under the federal Endangered Species Act, which would meaningfully contribute to giraffe conservation by strictly regulating the import, export, and interstate commerce in giraffes and their parts and products. See 16 U.S.C. 1531(b),(c) (providing that federal agencies shall utilize their authorities in furtherance of the conservation purpose of the ESA). Respectfully Submitted, Tanya Sanerib Center for Biological Diversity (503)-544-8512 Mark Hofberg International Fund for Animal Welfare (202)-536-1906 Masha Kalinina Humane Society International (301)-258-1521 Paul Todd Natural Resources Defense Council (212)-727-4651

Anna Frostic The Humane Society of the United States (202) 676-2333

Executive Summary TABLE OF CONTENTS I) Introduction II) Taxonomy III) Natural History and Biology A) Morphology B) Behavior C) Reproduction D) Feeding and Ecology E) Habitat Requirements IV) Population Status and Distribution A) Giraffe (Giraffa camelopardalis) B) West African Giraffe (Giraffa camelopardalis peralta) C) Kordofan Giraffe (Giraffa camelopardalis antiquorum) D) Nubian Giraffe (Giraffa camelopardalis camelopardalis) E) Reticulated Giraffe (Giraffa camelopardalis reticulata) F) Rothschild s Giraffe (Giraffa camelopardalis rothschildi) G) Masai Giraffe (Giraffa camelopardalis tippelskirchi) H) Thornicroft s Giraffe (Giraffa camelopardalis thornicrofti) I) Angolan Giraffe (Giraffa camelopardalis angolensis) J) South African Giraffe (Giraffa camelopardalis giraffa) V) Threats A) Present or Threatened Destruction, Modification, or Curtailment of its Habitat or Range B) Overutilization for Commercial, Recreational, Scientific, or Educational Purposes 1) International Trade for Commercial, Recreational, or Scientific Purposes 2) Online Sales of Giraffe Products 3) Widespread Bushmeat Trade in Giraffe 4) Giraffe Hair and Tail Trade C) Disease and Predation D) Inadequacy of Existing Regulatory Mechanisms 1) International Law and Agreements 2) Regional Agreements 3) National Laws E) Other Natural or Manmade Factors Affecting its Continued Existence VI) Conclusion

Executive Summary This Petition presents substantial information indicating that the giraffe (Giraffa camelopardalis) is currently in danger of extinction throughout all or a significant portion of its range and meets the statutory criteria for an endangered listing under the Endangered Species Act (ESA), 16 U.S.C. 1531-1544. The Petitioners the Center for Biological Diversity, Humane Society International, The Humane Society of the United States, International Fund for Animal Welfare, and Natural Resources Defense Council therefore petition the Secretary of the Interior and the U.S. Fish and Wildlife Service (the Service) to protect the giraffe as an endangered species under the ESA; or alternatively, if taxonomic consensus changes or the Service decides to list an entity below the species level, we request that all giraffe subspecies or distinct population segments be protected at least as threatened, with qualified subspecies or distinct population segments protected as endangered. The ESA requires the Secretary to determine within 90 days of receiving a petition whether the petition presents substantial scientific or commercial information indicating that the petitioned action may be warranted. 16 U.S.C. 1533(b)(3)(A). Such determination must be made solely on the basis of the best scientific and commercial data available. Id. 1533(b)(1)(A). Following a positive 90-day finding, the Secretary must, within one year of receipt of the petition, complete a review of the status of the species, publish a finding of whether the petitioned action is warranted and, if so, promptly propose a rule to list the species. Id. 1533(b)(3)(B). Should a rule be proposed, the Secretary has an additional year to finalize regulations protecting the species. Id. 1533(b)(6)(A). Once foreign species are listed as endangered, protection under the ESA occurs by, inter alia, prohibiting import, export, and interstate commerce in live animals and derivatives, 16 U.S.C. 1538(a)(1), (c), (g), unless such activity enhances the propagation or survival of the species or is for conservation science purposes. Id. 1539(a)(1)(A). Furthermore, Section 8 of the ESA provides for International Cooperation in the conservation of foreign species, and listing foreign species heightens global awareness about the importance of conserving the species. Id. 1537. This is essential for an animal like the giraffe where the public is generally unaware of its population decline. The Petition lays out the taxonomic status of the giraffe species, its natural history and biology, and the current status, distribution, and population trends. The Petition describes the threats facing giraffes including habitat destruction and fragmentation; overutilization through illegal hunting, legal sport hunting, and for use in international trade; disease and predation; and the inadequacy of the current regulatory mechanisms. The combination of these threats puts the conservation status of the species at risk. Listing the giraffe as endangered is necessary to prevent the decline of the species and promote its conservation both in the U.S. and in giraffe range countries, as required by law. Taxonomy, Status, and Distribution Currently, consensus on giraffe taxonomy is evolving. Numerous and varied recommendations exist in the scientific literature to change the longstanding taxonomy recognizing one species of giraffe (Giraffa camelopardalis), varying upon the weight given to morphological features, i

genetic data, and biological considerations. In classifying the giraffe as vulnerable to extinction in December,, the IUCN Giraffe and Okapi Specialist Group recognized one species (Giraffa camelopardalis) and nine subspecies: West African (Giraffa camelopardalis peralta); Kordofan (G. c. antiquorum); Nubian (G. c. camelopardalis); reticulated (G. c. reticulata); Rothschild s (G. c. rothschildi); Masai (G. c. tippelskirchi); Thornicroft s (G. c. thornicrofti); Angolan (G. c. angolensis); and South African (G. c. giraffa). Thus, this Petition addresses the giraffe species as a whole but, where relevant, also provides information on the nine subspecies. Giraffes once occupied much of the savannah and savannah woodlands of Africa. Today, the species only retains a fraction of that expansive range due to human population expansion. Current giraffe range includes isolated parts of West and Central Africa, increasingly fragmented habitat in East Africa, and parts of southern Africa. According to the IUCN s most recent estimate (), the giraffe has undergone a 36 to 40% population decline over the past 30 years. Today, roughly 97,500 giraffes remain in Africa compared to the over 150,000 giraffes recorded in Africa in 1985/ or within the last three generations. Threats Giraffes have experienced severe habitat loss and fragmentation as a result of the expansion of human activities into their habitats. The conversion of native habitat to agriculture, uncontrolled timber harvest, poor land use planning, and urban expansion have all played a role in the loss and degradation of giraffe habitat. Giraffes are hunted both legally and illegally for sport and for their parts and products. Most range countries nominally protect the species, but a lack of enforcement of local laws, in addition to civil unrest in certain parts of giraffe habitat have allowed poaching for bushmeat, bones, tail hair, and other parts to become a leading cause of giraffe mortality and major contributor to their decline. Poaching, as well as legal sport hunting, is further spurred by the international trade in giraffe parts and products, which is quantified in this Petition through original analysis of data from the Service s LEMIS database and an assessment of online sales of giraffe products. The online sales assessment and LEMIS data review show only a small part of the international trade in giraffes. Through available LEMIS data, it is clear that the U.S. is contributing to giraffe population decline. Over the past decade, the U.S. imported 21,402 bone carvings, 3,008 skin pieces, and 3,744 hunting trophies. The original analysis presented in this Petition shows that between 2006 and 2015 (the most recent decade for which complete data are available), 39,516 giraffe specimens (giraffes, dead or alive, and their parts and derivatives) were imported to the U.S. for all purposes. This equates to a very conservative, bare minimum equivalent of at least 3,751 giraffes. The equivalent of approximately 3,718 giraffes were imported for recreational or commercial purposes, and a staggering 20,885 giraffe bone carvings were imported for commercial purposes during the period studied. Further, because the giraffe is not listed on the Appendices of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), the scale of the global trade is unknown, but considering the volume of trade in other African wildlife species it is very likely to many times the size of the U.S. market alone, compounding the threat that international trade poses to this species. ii

Giraffes are further threatened by the proliferation of disease including the Giraffe Skin Disease (GSD), inbreeding depression in isolated populations, collisions with automobiles and airplanes, and the increased frequency and magnitude of droughts associated with climate change. Conclusion The Vulnerable classification of the giraffe by the IUCN in was a wake-up call to the world that the tallest land mammal on earth is undergoing a silent extinction due to widespread poaching, legal hunting, habitat loss and fragmentation, and other factors. With fewer giraffes left in Africa than elephants, it is imperative that we turn our attention to these unique animals before it is too late. Because the U.S. is a conservation leader and also a significant giraffe product consumer, conservation of these rare mammals can and should start here. This Petition clearly shows that the best available science and data unequivocally confirms that the giraffe meets the statutory requirements for listing as endangered under the ESA. The U.S. can end its role in the international trade of giraffe parts and products, while bringing further awareness to the rapid decline of one of the most well-recognized and celebrated icons of African biodiversity. iii

I) Introduction Best known for their long necks and distinctive coat patterns, giraffes (Giraffa camelopardalis) are fascinating mammals that have long captured the human imagination. They are the tallest land mammals with the highest blood pressure and long tongues reaching up to 50.8 cm (20 inches) that aid in browsing on a wide variety of trees and shrubs. The past decade has seen an increase in scientific research into these mammals, which has revealed that shockingly few giraffes remain in the wild. Deemed the silent extinction by the head of the IUCN s Giraffe and Okapi Specialist Group, 1 the IUCN at the end of announced that the giraffe population has suffered a 36-40% population decrease over the last thirty years. An estimated 97,560 giraffes remain in sub-saharan Africa distributed in small populations ranging from Niger to Kenya and south to South Africa. This population decline is attributed to habitat loss and fragmentation, and overutilization of giraffes particularly for bushmeat but also for hair and in international trade ranging from bones to sport-hunted trophies. Civil unrest and a growing human population with its consequent land use changes (e.g., increased agricultural fields, mining, and logging/land clearing) have both contributed to habitat loss and the increase in illegal killing (poaching) of giraffes. Current regulatory mechanisms fail to protect giraffes as evidenced by ongoing population declines, habitat loss, and other threats. As a significant importer of giraffes and their parts, and as a global leader in conservation, the U.S. can make a large and positive impact on the international trade of the species. An endangered listing for giraffe will help the species in a number of ways. Perhaps most importantly, it will better regulate the import to and export from the U.S. of giraffe parts (e.g., bone, skin, hair, feet, tails), sport-hunted trophies, live giraffes, etc. for commercial import/export and require enhancement authorization for trophies. This is especially important given that imports in giraffe trophies and parts have increased in recent years, with 39,516 giraffe specimens the equivalent of at least 3,751 giraffes imported into the U.S. between 2006 and 2015, as described in more detail in Section V.B. An endangered listing will also help regulate the interstate trade in giraffe trophies and parts, which appears to be growing with at least 1,224 giraffe parts available for sale online in the U.S. over a period of less than one month, including skeleton parts and products made from giraffe bone, hair, and skin. ESA protections will also benefit giraffe by increasing worldwide awareness of its plight and generating potential funding for scientific research and in-situ conservation of the species in range countries. While scientists continue to unravel the genetics of giraffes and finally determining whether multiple giraffe species exist, the current taxonomic consensus supports recognizing one species of giraffe and nine subspecies. Thus, we petition for an endangered listing of the giraffe species due to the small and declining population over a significant portion of the species range, wide spread habitat loss and fragmentation, and overutilization of giraffe. If taxonomic consensus changes or the Service decides to list an entity below the species level, we request that all giraffe subspecies or distinct population segments be protected at least as threatened, with qualified subspecies or distinct population segments protected as endangered. 1 As quoted in the Washington Post and other media outlets. (https://www.washingtonpost.com/news/morning-mix/wp//12/08/silent-extinction-giraffes-listed-asa-vulnerable-species-after-30-year-population-plunge/?utm_term=.7e2dda22601b). 1

II) Taxonomy Giraffe belong to the mammalian order Cetartiodactyla and the family Giraffidae (Mitchell et al., 2003). This family consists of two living genera, Giraffa and Okapia, which are both native to the African continent (ibid.). These two genera diverged from a common ancestor roughly 11.5 million years ago (Agaba et al.,, p. 2). The giraffe was formally described by Linneas in 1758 based on an earlier description of a captive giraffe in Cairo (Seymour, 2012, p. 5). Linneas originally placed giraffe in the Cervidae genus along with elk and deer, but it was later reclassified to the currently used nomenclature Giraffa camelopardis in 1848 (ibid.). Throughout much of the 1800s, giraffes were considered to be represented by two species based on descriptions of pelage patterns from a skin collected in southern Africa and another collected in northern Africa (ibid.). As more specimens became available for scientific description, various new taxonomies were put forward including alternative species descriptions as well as subspecies descriptions (see for example de Winton, 1899; Thomas, 1901; Lydekker, 1904, 1911; Krumbeigel, 1939 as described by Seymour 2012). Eventually, the commonly accepted taxonomy settled around a single species, Giraffa camelopardis, and nine subspecies as described by Dagg (1971, p. 1). Although subsequent treatments have proposed additional alternatives (including East, 1999 and Grubb, 2005), Dagg (1971) has continued to remain the most commonly referenced taxonomy for the giraffe. These early descriptions of giraffes were based primarily on morphological traits including pelage patterns and skull size including ossicone (horn like structures) measurements, as well as the geographic distribution of this morphological variation across the African continent (Lydekker, 1904, 1911; Dagg, 1971; East, 1999; Grubb, 2005). More recently, genetic analyses have added to morphological data to further inform the possible taxonomy of giraffes (Hassanin, et al., 2007, p. 267; Brown et al., 2007, p. 3; Brenneman et al., 2009, p. 721; Fennessy et al., 2013, p. 636; Bock et al., 2014, p. 1; Fennessy et al.,, p. 1; Bercovitch et al., 2017, p. 1). In 2007, Hassanin et al. sequenced mitochondrial DNA from 23 individuals across six of the various subspecies range. The authors continued to recognize the previously described subspecies, but did suggest redefining the geographical separation between the western G. c. peralta and the central G. c. antiquorum subspecies. Similarly, Bock et al. (2014, p. 10) used mitochondrial DNA sequences from 161individuals across eight of the described subspecies and found strong genetic structuring between subspecies, but did not propose a new taxonomy. They did however propose refining the geographic limits between the Angolan G. c. angolensis and the South African giraffe, G. c. giraffa. Their results indicated that the range of the South African giraffe may extend further north than previously thought to include several populations of giraffe in Botswana, Namibia, Zambia, and Zimbabwe that were historically considered Angolan (Bock et al., 2014, p. 2; see also Brenneman et al., 2009, p. 721). Brown et al. (2007, p. 3) sampled six of the nine subspecies described by Dagg (1971) and found clear genetic differentiation between all six subgroups based on both mitochondrial DNA sequences as well as 14 nuclear microsatellite loci. In addition, Brown et al. (2007, p. 7) found a near absence of hybrids even between parapatric subspecies. The combination of genetic and phenotypic differentiation along with the absence of hybridization led the authors to conclude that the giraffe might represent more than one species. The authors suggest recognizing the six subspecies that they sampled as evolutionarily significant units if not species (Brown et al., 2

2007; p. 57) and they suggest that additional taxonomic units could be recognized if the remaining described subspecies were also sampled. The lack of hybridization between the recognized subspecies of this highly mobile and transient animal is striking and suggests both a history of separation and the presence of pre-mating isolating mechanisms. Subspecies are expected to demonstrate some level of introgression, or genetic exchange. However, Bock et al. (2014, p. 9) identified clear matrilineal structuring of distinct clades and limited evidence for haplotype sharing between subspecies indicating very little to no genetic exchange between subspecies. In fact, Bock et al. (2014, p. 8) suggest that the few individuals whose haplotypes differed from their assigned subspecies could be attributable to human translocation or misidentifications. Brown et al. (2007, p. 3) also found strong genetic subdivisions between described subspecies using both mitochondrial DNA sequence as well as nuclear microsatellites. The authors theorized that behavioral isolation such as assortative mating based on pelage patterns of geographically proximate giraffes could explain these strong subdivisions (ibid.). This strong genetic structuring and near lack of hybridization even among parapatric subspecies lends support for the possible recognition of additional species within the giraffe complex. Based on the genetic data from Hassanin et al. (2007, p. 266) and Brown et al. (2007, p. 3), Groves and Grubb (2011) superimposed their morphological data to suggest the recognition of eight distinct species of giraffe. Finally, most recently, a genetic study based on more extensive sampling of all nine described subspecies asserted that giraffe are actually composed of at least four different species and five subspecies (Fennessy et al.,, p. 2). The authors examined mitochondrial DNA sequence data as well as nuclear intron sequence data and discovered deeply structured genetic groups. This newly proposed taxonomy, however, is still subject to scientific debate (see Bercovitch et al., 2017). A variety of different taxonomies have been proposed to describe giraffe over the past several centuries and even the last few decades. The lack of consensus on this topic largely has to do with the fact that each individual study has been based on different, and often incomplete, sampling of populations as well as the examination of different types of data. Although Fennessy et al. (, p. 2) presents one of the most extensive studies to date both in terms of individuals, populations, and genetic sampling, there is still some dispute as to whether all of the populations, or putative subspecies, were sampled adequately (Bercovitch et al., 2017, p. 1). Additionally, Fennessy et al. (, p. 5) largely relies on molecular markers that help to distinguish differentiation at the species level and above, but may not, for example, be adequate for distinguishing below species level differentiation at the subspecies and population level. Finally, Fennessy et al. (, p. 2) largely ignore other taxonomically informative data such as geography, ecology and morphology. Given the ongoing investigations into the taxonomy of giraffe, the IUCN giraffe assessment concluded that, Until an extensive reassessment of the taxonomic status of giraffes is completed... it is premature to alter the taxonomic status quo (Muller et al., ; p. 1). The authors write that [t]he IUCN SSC Giraffe and Okapi Specialist Group (GOSG) currently recognizes a single species, Giraffa camelopardalis and that [n]ine subspecies of Giraffes are currently recognized (ibid., p.1). This consensus statement is significant as the specialist group is made up of many of the leading researchers on giraffe taxonomy including several who have proposed alternative and competing taxonomies. 3

Therefore, while the precise taxonomy of giraffe at the species and subspecies level remains a topic of active scientific research and debate, the consensus scientific opinion from the leading international giraffe experts is to recognize one species, Giraffa camelopardis, with nine subspecies: West African (G. c. peralta); Kordofan (G. c. antiquorum); Nubian (G. c. camelopardalis); reticulated (G. c. reticulata); Rothschild s (G. c. rothschildi); Masai (G. c. tippelskirchi); Thornicroft s (G. c. thornicrofti); Angolan (G. c. angolensis); and South African (G. c. giraffa) (Dagg, 1971; Dagg & Foster, 1976). Accordingly, this is the taxonomy that we follow in this petition and that we request the Service evaluate in their finding. III) Natural History and Biology A) Morphology Giraffes are best known for their long necks, long legs, long dark tongues, and distinctive coat patterns. Their necks and tongues enable them to reach and process forage that few other mammals can access (Pretorius et al., 2015, p. 1; Simmons & Altwegg, 2010, p. 6-7), but their neck length may also have been sexually selected because it increases the likelihood of success among males in competition for dominance and access to females (Simmons & Scheepers, 1996, p. 771-72). Giraffes coats and their unique patterns may help them identify kin (Bercovitch & Berry, 2013, p. 4 (Herd Composition)). Giraffes also have long legs and are the tallest land mammal, with males and females averaging 5.3 meters and 4.3 meters respectively (Nowak, 1999, in Seymour, 2001, p. 71). Males weigh roughly 1,200 kg and females roughly 830 kg (Owen-Smith, 1992, in Seymour, 2001, p. 71). Due to their height, giraffes have the highest blood pressure of any land mammal. Their height also poses challenges for drinking water or reaching resources on the ground because their necks do not bend low enough to reach land. As a result, giraffes kneel or splay their legs to reach the ground or water (Seeber et al., 2012, p. 1). Giraffes have special physiological adaptations to regulate blood flow to the brain depending upon the height of the head to ensure they do not pass out while bending down (Brondum et al., 2009, p.1058-59). They are most vulnerable to predation when reaching to the ground because of their inability to kick, which is their primary defense (Periquet et al., 2010, p. 670; Seeber et al., 2012, p. 1). Giraffes are born with their ossicones (a morphological feature that is akin to horns but unique to giraffids and also referred to as parietal horns). The ossicones only fuse to their skull when they reach sexual maturity (Davis et al., 2011, p. 6). Adolescent male giraffes have hair on their ossicones that wears off leaving adult males with bald ossicones while female s ossicones have hair. Giraffes also have median ossicones or bumps in the middle of their foreheads and may have small ossicones on the back of the skull called occipital ossicones (Spinage, 1968, p. 55-58). As detailed above, Dagg (1971) classified nine separate subspecies of giraffe based on morphology and, until recently, this classification was the most frequently consulted for the status of giraffe taxonomy (Dagg, 1971, p. 1; Seymour, 2012, p. 6). The nine species have been delineated based on coat pattern, head shape, and ossicones. Table 1 describes morphological 4

differences in each of these subspecies relating to the coat pattern (or pelage) and differences in ossicones and skull shapes. Table 1: Giraffe subspecies differences in morphology (Seymour, 2001). Subspecies Coat Pattern Distinguishing features West African giraffe (G. c. peralta) Body spots are large coarsely divided lobes. Spots extend down the legs beyond the hocks. Parietal ossicones diverge and are more erect compared to other subspecies. Males have a well-developed median ossicone and females have a bony structure over the frontal bones. (Seymour, 2001, p. 52). Kordofan giraffe (G. c. antiquorum) Spotting is similar to G. c. camelopardalis but spots are smaller and less regular. Spotting is present on the insides of the legs and sometimes extends below the hocks. Males have a median ossicone. (Seymour, 2001, p. 51). Nubian giraffe (G. c. camelopardalis) Chestnut colored body spots are smooth and strongly defined. The belly is free of spotting, while the sides of the head are spotted. Males have a developed median ossicone. (Seymour, 2001, p. 51). 5

reticulated giraffe (G. c. reticulata) Large spots are reddish-brown, welldefined, polygonal, and separated by a network of white lines. Males have a median ossicone. (Seymour, 2001, p. 53). Rothschild's giraffe (G. c. rothschildi) Large dark body spots usually have complete margins, with spots tending to break up with radiating lines inside the dark spots. The occipital ridge develops into paired occipital ossicones which may be individually variable. Males have a welldeveloped median ossicone. (Seymour, 2001, p. 53). Masai giraffe (G. c. tippelskirchi) Body spots are can be reticulate as well as stellate, and intermediate, and leg spots continue down to the hooves. The males typically have a median ossicone, but the presence is individually variable. (Seymour, 2001, p. 54). Thornicroft s giraffe (G. c. thornicrofti) Body spots are slightly stellate. Neck spots are typically elongated, while legs may be fully spotted or uniformly colored. Males have little developed and unobtrusive median ossicones. (Seymour, 2001, p. 54). 6

Angolan giraffe (G. c. angolensis) Large brown body spots have slightly notched edges. Spots on the neck and rump are broken into smaller spots. Spotting is present on the legs and lower half of face, and a small white ear patch is present. Males are two-ossiconed. (Seymour, 2001, p. 51). South African giraffe (G. c. giraffa) Dark body spots with some fine projections occur on a tawny ground color. Spotting is present on legs and decreases in size further down the legs. The males do not have a well-developed median ossicone. (Seymour, 2001, p. 52). Coat pattern images by Amada44/Wikipedia, CC-BY-SA B) Behavior Giraffes are social animals and non-territorial in nature (Van der Jeugd & Prins, 2000, p. 19; VanderWaal et al., 2014, p. 23). Their ranges vary in size depending upon available habitat and food resources (McQualter et al., 2015, p. 100). Giraffes move through their range usually in herds. Giraffe herds were long thought to be casual associations but recent research indicates that they live in fission-fusion societies such as elephants and other species (Bercovitch & Berry, 2013, p. 6 (Herd Composition)). Researchers are just beginning to investigate whether giraffes vocally communicate with one another, as is common in fission-fusion societies (Baotic et al., 2015, p. 2-3). Recent work by Baotic et al. (2015, p. 8-9) documented that giraffes engage in a low-frequency, highly structured hum at night, which may provide a window into giraffe communication. Historically, large herds of 20-30 animals were commonly seen and, while herds of over 50 giraffes can occasionally still be seen today in open areas, smaller herds are most common (Muller et al.,, p. 5). Bercovitch and Berry (2013, p. 6 (Herd Composition)) found that giraffe herds typically have five to six animals but size varies depending upon resource availability. Herds of females are more common than female-male groupings or male-male groupings (ibid.).the authors have shown that giraffe herds are more often based on lengthy social associations, often of kin or closely related giraffes (ibid., p. 6-7). Females share responsibilities for caring for young giraffes (allomothering) with related and unrelated giraffes 7

(ibid.). Giraffes born around the same time as each other to the same cohort form strong bonds and often will remain in herds together (Bercovitch & Berry, 2013, p. 4 (Age Proximity). The oldest adult female, or matriarch, is mostly likely the leader of a giraffe herd (Berry & Bercovitch, 2014, p. 179). Male giraffes tend to be more solitary upon leaving their natal herds (Bercovitch et al., 2006, p. 314). To prepare for dominance battles, young males engage in sparring and duels involving intertwining of necks as each opponent assesses the other s strength (called necking) (Pratt & Anderson, 1982, p. 486; Coe, 1967, p. 315). When males are older they may engage in necking or more aggressive fighting that entails knocking heads and tackling each other with their ossicones. The fighting usually ends when the losing opponent walks away leaving the winner to establish dominance (ibid., p. 317, 320). Giraffes browse on a very wide number of different types of trees and scrubs (Dagg & Foster, 1976; Pellew, 1983; Fennessy, 2009, p. 320). Females spend a large part of the day and some of the night browsing, while males browse and search for females. Giraffes spend around 13 hours per day browsing and roughly 4.5 hours a day ruminating (Mitchell et al., 2015, p. 125). Giraffes can sit with their feet tucked under the body while the head remains upright. Actual sleep consists of very short naps during which time the giraffe curves its neck and lays its head on its flank (Pellew, 1984, p. 65). C) Reproduction Female giraffes give birth throughout the year (Dagg & Foster, 1972, p. 9). Pregnancy lasts about 15 months, and generally there are two-year intervals between births (Bercovitch & Berry, 2009, p. 535). First parturition occurs when the female is between five and seven years old (ibid.; Bercovitch & Berry, 2015, p. 207). Males reach sexual maturity at seven to eight years of age (Bercovitch & Berry, 2012, in Dagg, 2015, p. 144). Males travel extensively to investigate and detect females receptive to mating (Bercovitch et al., 2006, p. 315). To determine which female is ready for courting and mating, male giraffe stimulate female urination and will sample the females urine (flehmen), which is followed by attempts to mount females in estrus (Leuthold, 1979, p. 30). When giving birth, the female stands letting the calf fall to the ground (Dagg, 2015, p. 136). Female giraffes typically give birth to just one calf at a time with an average calf weighing five kg and with an average height of 1.8 m at birth (Dagg & Foster, 1982 in ibid.). The calf is able to stand within the first twenty minutes and can start suckling about an hour after birth (Kristal & Noonan, 1979, p. 105). Giraffes are most vulnerable to predation during the first year of life, although predation remains a threat throughout a giraffe s life (Strauss & Packer, 2013, p. 134). Bercovitch and Berry (2009, p. 538) concluded that reproductive rate is not as important as the survival of calves and longevity in terms of reproductive success. Mothers may leave their young in a cluster called a crèche or nursery to protect the calves from predation while they feed (Strauss & Packer, 2013, p. 134; Young & Isbell, 1991, p. 80). Young giraffes can be weaned as early as one month, although they may suckle for much longer (Foster & Dagg, 1972, p. 8). 8

D) Feeding and Ecology Giraffes are browsers, spending between 40 to 85 percent of their time feeding primarily on new shoots, leaves, twigs, fruit, and grasses (Ciofolo & Pendu, 2002, p. 191; Pellew, 1984, p. 62; Zinn et al., 2007, p. 124). Giraffes forage varies largely depending on the time of the year and the giraffe s location. Males browse at a higher feeding height than females (O'Connor et al., 2015, p. 190). Due to their height, elephants are the only other mammals that compete with giraffes for food at the tree level; however giraffe compete with kudu and impala at the shrub level of habitats (Pellew, 1984, p. 59; Sauer et al., 1977, p. 58). Giraffes generally feed on succulent vegetation and are thought to be able to live for extended periods without fresh water although they will drink water when it is available (Foster & Dagg, 1972, in Dagg, 2015, p. 15). Apart from acacia species, giraffes consume a variety of vegetation types and have been found to eat up to 93 different species of trees, scrubs, and plants (Ciofolo & Pendu, 2002, p. 187; Mueller et al.,, p. 6; Parker & Bernard, 2005, p. 207). Giraffes have been observed licking soil near termite mounds likely for their high salt content and may chew on bones (Ciofolo & Pendu, 2002, p. 187). E) Habitat Requirements Giraffes can be found throughout sub-saharan Africa but are primarily located in savanna and woodland habitats (Mueller et al.,, p. 6). Giraffes can have large home ranges where they encounter a wide variety of vegetation types (Skinner & Smithers, 1990, in Parker & Bernard, 2005, p. 207). There are differences in habitat preferences between sexes due to males preferring habitats offering taller browse, while females select habitats with lower browse (Pellew, 1984b, p. 62). Giraffes do not need to drink water every day (Mueller et al.,, p. 6), but tend to stay in areas near rivers especially during the dry season because these areas offer permanent food and water supply (Fennessy, 2004, p. 199; Leuthold & Leuthold, 1978, p. 18). Giraffes also tend to avoid areas where predators, especially lions and leopards, may be located and prefer open scrub and open woodlands as habitats less likely to contain predators (Thaker et al., 2011, p. 403). Giraffes are vulnerable to predators when drinking water and maintain a high level of vigilance for predators when at watering holes (Creel et al., 2014, p. 9; Periquet et al., 2010, p. 670). IV) Population Status and Distribution A) Giraffe (Giraffa camelopardalis) 1) Distribution The historic distribution of Giraffa camelopardalis is thought to include much of the semi-arid savannah and savannah woodlands of Africa (Dagg, 1971, p. 1; East, 1999, p. 99). Giraffes today are found south of the Sahara and only maintain a fraction of their range due to human population expansion and increased aridity (Muller et al.,, p. 2; Dagg, 1971, p. 1). In West Africa, giraffes historically ranged from Senegal to Lake Chad, but now only a small population 9

of the West African giraffe (G. c. peralta) remains in Niger (Suraud et al., 2012, p. 577). In Central Africa, giraffes remain in some protected areas and their surrounds in southern Chad, northern Cameroon, northern Central African Republic (CAR), South Sudan, and northeastern Democratic Republic of the Congo (DRC) (Muller et al.,, p. 2). In East Africa, the giraffe range has been severely reduced in Ethiopia, Somalia, South Sudan, and Uganda, but has remained relatively stable in Kenya and Tanzania (East, 1999, p. 97-98). An isolated, but stable, population of Thornicroft s giraffe (G. c. thornicrofti) persists in northeastern Zambia (Du Raan et al., 2015, p. 7; East, 1999, p. 98). In southern Africa, giraffes retain much of their range in Namibia, Botswana, South Africa, and Zimbabwe, but were severely reduced or even extirpated in Angola and Mozambique (East, 1999, p. 98-99). Giraffes have been translocated into protected areas in several countries both within their native range (northeastern South Africa, Kenya, Uganda, Mozambique, Angola, northeastern Zambia, and others) and outside their range (parts of South Africa, southwestern Zambia, Swaziland, and Rwanda). Map 1 Current Range of Giraffe 10

2) Population Status In, the IUCN Red List of Threatened Species updated its assessment of Giraffa camelopardalis to Vulnerable, citing an ongoing population decline between 36% and 40% over the last 30 years or three generations (Muller et al.,, p. 1). The previous IUCN assessment, conducted in 2010, considered the species of Least Concern, but two subspecies (G. c. peralta and G. c. rothschildi) were assessed as Endangered in 2008 and 2010 respectively (Muller et al.,, p. 1-2; Shorrocks,, p. 40). Historic estimates of giraffe population sizes show a precipitous population decline at the species level. The IUCN Species Survival Commission (SSC) Giraffe and Okapi Specialist Group and the Giraffe Conservation Foundation (GCF) estimate that giraffes numbered between 151,702 and 163,452 in the 1980s (Muller et al.,, p. 4). East (1999, p. 100) estimated that there were approximately 141,000 giraffes in the wild in the 1990s. The IUCN s most recent (2015) estimate places the giraffe population at 97,562 individuals (Muller et al.,, Table 1). And while the overall population is trending downward, the trends vary significantly at regional and subspecies levels. B) West African Giraffe (Giraffa camelopardalis peralta) 1) Distribution The West African giraffe subspecies (G. c. peralta) formerly ranged from Senegal to Lake Chad in savannah zones including Burkina Faso, Guinea, Mali, Nigeria, Niger, and other West African countries (East, 1999, p. 99). Due to anthropogenic pressures including habitat loss, fragmentation, and overexploitation, only a small population remains in the arid Sahelian scrubland of southwestern Niger (Marais et al., 2014, p. 1 (Niger)). 2) Population Status Since the Niger population plummeted to fewer than 50 giraffes in 1996, the Government of Niger has strictly protected the population by increasing enforcement of laws against hunting giraffe and improving community awareness (Suraud et al., 2012, p. 577). As a 11

result, the population has seen very little poaching and steady growth in recent years (ibid.), with an estimated 220 giraffes in 2009, 310 giraffes in 2011, and 403 giraffes in 2013 based on aerial surveys (ibid.; Marais et al., 2014, p. 4-5 (Niger)). This high growth rate may be unsustainable once the population hits carrying capacity due to lack of habitat and human encroachment (Suraud et al., 2012, p. 581). The IUCN recognized the subspecies as Endangered in 2008 (Fennessy & Brown, 2008). Fennessy et al. (, p. 2) estimates about 400 West African giraffes remain, making this subspecies one of the most imperiled despite its recent growth. C) Kordofan Giraffe (Giraffa camelopardalis antiquorum) 1) Distribution The Kordofan giraffe subspecies (G. c. antiquorum) former range includes a large swath of the open savanna woodlands of Central Africa from northern Cameroon through central and southern Chad, CAR, South Sudan, and northern DRC (East, 1999, p. 96-97). 2 Human activities including development, agriculture, and logging have restricted Kordofan giraffe range to isolated protected areas (ibid.). The Kordofan giraffe is presently found in the northern savannah of the Central African Republic and across the border into southern Chad, primarily in Zakouma National Park (Marais et al., 2012, p. 1 (CAR); Marais et al., 2014, p. 3 (Chad)). This subspecies is also found in the northern extremes of Cameroon, mostly in Waza National Park (Marais et al., 2013, p. 3 (Cameroon)). A small, isolated population also resides in DRC s Garamba National Park and adjacent hunting reserves bordering South Sudan (Marais et al., 2013, p. 1 (DRC)). In South Sudan, giraffe are found in Boma National Park and other protected areas towards the southern extent of the country, although it is not known if this population is G. c. antiquorum or another species (Marais et al., 2012, p. 4 (South Sudan)). 2 East (1999) referred to both G. c. antiquorum and G. c. peralta as western giraffe, but G. c. antiquorum is now considered Kordofan giraffe (Marais et al., 2013, p. 2 (Cameroon)). 12

2) Population Status The IUCN s assessment of G. c. antiquorum estimated 3,696 individuals between 1975 and 1986 (Muller et al.,, p. 5). The assessment estimates that as of, the total population is approximately 2,000 individuals, translating to a 46% decline over the last three to four decades (ibid.). In the CAR, the Kordofan giraffe population has declined extremely rapidly despite suitable landscape and low human population due to bushmeat hunting and trade (Marais et al., 2012, p. 3 (CAR)). In 1985, it was estimated that 1,757 Kordofan giraffes resided in the country (ibid.), but a 2010 aerial survey of wild mammals in the CAR s northern protected areas estimated only 162 Kordofan giraffes remain (Bouche et al., 2012, p. 7005). In Chad, Kordofan giraffe formerly occurred widely in the central and southern parts of the country, but now survive primarily in Zakouma National Park where a 2014 aerial count found 934 individuals (Marais et al., 2014, p. 3 (Chad)). Zakouma National Park is managed by African Parks (African Parks, ) and the GCF determined that this population seems stable and relatively well protected (Marais et al., 2014, p. 3 (Chad)). Any populations outside of Zakouma National Park are small and vulnerable (ibid.). In Cameroon, Kordofan giraffes formerly occurred throughout the northern savannah woodlands and Sahel zone (East, 1999, p. 96). 3 However, illegal hunting, conflict, population growth, and habitat destruction have restricted giraffes to a main population in Waza National Park and minor populations in other northern protected areas (Marais et al., 2013, p. 2 (Cameroon)). GCF s 2013 assessment of Cameroon giraffes estimates that fewer than 660 remain, with about 600 in Waza National Park and about 50 in other parks (ibid., p. 3). In the DRC, giraffes formerly occurred throughout the northern Congo savannas (Marais et al., 2013, p. 3 (DRC)). Currently, giraffes are restricted to Garamba National Park and surrounding hunting reserves (ibid., p. 4). As recently as the early 1990s, there were approximately 350 giraffes in the park (ibid., p. 3). However, following years of conflict and illegal hunting in the region, a 2012 aerial count of the park and surrounding hunting reserves counted only 22 giraffes (Bolaños, 2012, p. 9). Bolaños states that this may be a moderate undercount, but it is clear that giraffe numbers in the area have fallen precipitously (ibid., p. 26-27). The GCF s 2013 assessment of DRC giraffe estimates that less than 80 remain in the entire country (Marais et al., 2013, p. 4 (DRC)). In South Sudan, giraffes were common throughout what was then southern Sudan, with Kordofan giraffe occurring west of the Nile River (East, 1999, p. 97). As recently as 1980, there were an estimated 9,028 giraffes in Boma National Park and several thousands in other parks (Fryxell, 1980, in Marais et al., 2012, p. 3 (South Sudan)). Presently, there is only one known major population of giraffe in the country, found in Boma National Park, consisting of fewer than 450 individuals (Marais et al., 2012, p. 4 (South Sudan)). There is uncertainty over whether this population is Kordofan or Nubian giraffe (ibid.). 3 East (1999) referred to both G. c. antiquorum and G. c. peralta as western giraffe, but G. c. antiquorum is now considered Kordofan giraffe (Marais et al., 2013, p. 2 (Cameroon)). 13

In summary, about 2,000 Kordofan giraffes remain when adding up the country by country estimates, with potentially 450 more depending on the subspecies of the South Sudanese population. In all range countries, this subspecies has seen a marked decline due to conflict, illegal hunting, and habitat degradation. D) Nubian Giraffe (Giraffa camelopardalis camelopardalis) 1) Distribution The Nubian giraffe subspecies (G. c. camelopardalis) historically occurred throughout South Sudan, southern and northeastern Sudan east of the Nile river, and through the western and southern lowlands of Ethiopia to the southwestern savannas of Eritrea (East, 1999, p. 97). Currently, the subspecies occurs in remnant populations in the far west of Ethiopia and potentially in east South Sudan; the population there is presumed to belong to either the Nubian or Kordofan subspecies (Marais et al., 2013, p. 3 (Ethiopia); Marais et al., 2012, p. 4 (South Sudan)). Giraffes are presumed to have been extirpated from Eritrea (Marais et al., 2014, p. 2 (Eritrea)). 2) Population Status The IUCN s assessment of G. c. camelopardalis estimated that Nubian giraffes numbered 20,577 between 1970 and 1982 (Muller et al.,, p. 5). The assessment estimates that as of 2015, the total population was approximately 650 individuals, translating to a 97% decline over the last 35 years (ibid.). In South Sudan, giraffes were common throughout what was then southern Sudan, with Nubian giraffe occurring east of the Nile River (East, 1999, p. 97). As recently as 1980, there were an estimated 9,028 giraffes in Boma National Park and several thousands in other parks (Marais et al., 2012, p. 3 (South Sudan)). At present, there is only one known major population of giraffes of fewer than 450 individuals, found in Boma National Park (ibid., p. 4). There is uncertainty over whether this population is Kordofan giraffe or Nubian giraffe (ibid.). 14

In Ethiopia, Gambella National Park is home to the country s primary remaining population of Nubian giraffes, which consists of approximately 90 individuals as of a 2009 aerial count (Marais et al., 2013, p. 3 (Ethiopia)). Several small populations of 20 individuals or fewer are thought to remain in Omo National Park and Tama Wildlife Reserve, but controversy remains about whether they are still there and what subspecies they are (ibid., p. 3-4; Renaud, 2007, p. 13) In summary, about 650 Nubian giraffes remain in the wild, making this subspecies one of the most imperiled. E) Reticulated Giraffe (Giraffa camelopardalis reticulata) 1) Distribution The reticulated giraffe subspecies (G. c. reticulata) historic range includes the southern lowlands of Ethiopia and Somalia, sweeping south into northern Kenya, bounded by the Tana River to the south (East, 1999, p. 97). Currently, G. c. reticulata maintains much of its historical range in Kenya, but overexploitation and habitat disruption have reduced giraffe range in Ethiopia to the protected areas bordering Kenya, and have probably led to extirpation in Somalia (Marais et al., 2013, p. 3 (Ethiopia); Marais et al., 2013, p. 2 (Somalia)). 2) Population Status The IUCN s assessment of G. c. reticulata estimated that the subspecies numbered anywhere between 36,000 and 47,750 in the 1990s (Muller et al.,, p. 5). The assessment estimates that as of, the current total population is approximately 8,661 individuals, translating to a 77-82% decline over the last 20-30 years (ibid.). In Kenya, historically large populations of reticulated giraffe have been reduced due to habitat destruction, fragmentation, and increased bushmeat consumption (Marais et al., 2013, p. 2 15

(Kenya)). As recently as the early 1990s, it was estimated that about 27,540 reticulated giraffes resided in northern Kenya mostly outside of protected areas (East, 1999, p. 95). More recent estimates show devastating losses. In Laikipia County, aerial surveys conducted between 2001 and 2012 estimate that the reticulated giraffe population declined by 36%, from 1,727 individuals in 2001 to 1,105 individuals in 2012 (Kinnaird et al., 2012, p. 6). In Garissa County, a 2011 aerial survey estimated 1,666 giraffe remained (King et al., 2011, p. 7). A 2013 GCF assessment collated recent aerial surveys of reticulated giraffe habitats in Kenya, including protected and private areas. The analysis estimated that fewer than 6,500 giraffes remain (Marais et al., 2013, p. 10 (Kenya)). In Ethiopia, it is uncertain whether a small reticulated giraffe population still remains; GCF estimated in 2013 that anywhere from zero to 100 reticulated giraffe remain in the country (Marais et al., 2013, p. 4 (Ethiopia)). In Somalia, all giraffe populations are presumed to be extirpated as of 2013 (Marais et al., 2013, p. 2 (Somalia)). In summary, combining the most recent estimates of reticulated giraffe populations leads to a total estimate of fewer than 9,000 individuals remaining, almost entirely in northern Kenya. The GCF has since updated their population estimate to 8,660 reticulated giraffes in (Fennessy et al.,, p. 2) and the IUCN assessment is in agreement (Muller et al.,, p. 5). As recently as the early 1990s, there was, at the very least, three times that number (East, 1999, p. 95), equating to a well over 70% decline over the last two decades. 16

F) Rothschild s Giraffe (Giraffa camelopardalis rothschildi) 1) Distribution The Rothschild s giraffe subspecies (G. c. rothschildi) historic range includes central-west Kenya through Uganda to the Nile River and into South Sudan (Marais et al., 2013, p. 5 (Kenya)). Currently, only one naturally-occurring population remains in Murchison Falls National Park in Uganda (ibid.). Other populations of the subspecies have been reintroduced into several sites in Kenya that are presumed to be in their natural range, including Ruma National Park, Lake Nakuru National Park, Mt. Elgon National Park, and several game farms and reserves (ibid., p. 7-8, 10-11). 2) Population Status The Rothschild s giraffe population has been severely reduced across its range, but is recovering due to conservation efforts. In 2010, the IUCN assessed the species as Endangered, citing population declines across its range (Fennessy & Brenneman, 2010, p. 2). The IUCN s assessment estimated a total population size of 1,330 G. c. rothschildi in the 1960s, increasing to 1,671 individuals in (Muller et al.,, p. 5). In Kenya, the subspecies had been nearly extirpated by the 1960s (Marais et al., 2013, p. 5 (Kenya)). Translocation and conservation efforts in the 1970s established protected and fenced areas for the animals in Kenya. Current population size estimates place the number of Rothschild s giraffe in Kenya at about 450 individuals split among several national parks and private conservation areas (ibid., p. 10-11; Muller, 2012, p. 4). In Uganda, G. c. rothschildi once thrived both inside and outside of protected areas. Illegal hunting, habitat degradation, and habitat destruction led to near extirpation in the 1970s and 1980s. Starting in the late 1980s, Uganda improved management and anti-poaching efforts, leading the giraffe population to steadily increase, primarily in Murchison Falls National Park (Rwetsiba & Nuwamanya, 2010, p. 120). From estimated low population sizes of 78 giraffes in 1991 (ibid., p. 122) and 145 in the late 1990s (East, 1999, p. 95), giraffes increased to 245 in 2005 (Rwetsiba & Nuwamanya, 2010, p. 122). Recent surveys have shown that the Murchison 17

Falls population has increased, with 904 individuals estimated in 2010 (ibid.) and 757 individuals estimated in 2012 (Marais et al.,, p. 4 (Uganda)) based on aerial surveys. The GCF s assessment of Uganda giraffe populations estimated that 1,250 individuals currently reside in Murchison Falls (ibid.). Other smaller populations exist in Kidepo Valley National Park and Lake Mburo National Park (ibid.). In summary, combining recent studies and surveys, it is estimated that approximately 1,700 Rothschild s giraffes remain. G) Masai Giraffe (Giraffa camelopardalis tippelskirchi) 1) Distribution The Masai giraffe subspecies (G. c. tippelskirchi) historically ranged across the open grasslands and woodlands of southern and eastern Kenya southwards through much of Tanzania to the Rufiji River (East, 1999, p. 98). The subspecies remains in southern Kenya and retains much of its historical range in Tanzania including the Serengeti, Tarangire, Ruaha, Kilamanjaro, and Lake Natron (East, 1999, p. 98; Okello et al., 2015, p. 160, 166). Additionally, there is an introduced population in Rwanda s Akagera National Park (Marais et al., 2012, p. 2 (Rwanda)). 2) Populations Status The IUCN s assessment of G. c. tippelskirchi estimated that Masai giraffes numbered 66,449 between 1977 and 1980 (Muller et al.,, Table 1). East (1999, p. 95) estimated that there were 46,210 Masai giraffes in the 1990s. The IUCN assessment estimates that as of 2015, the total population was approximately 31,611 individuals, translating to a 52% decline over the last 25-28 years (Muller et al.,, Table 1). In Kenya, G. c. tippelskirchi populations have seen sharp declines over recent decades. Kenya was home to an estimated 17,330 Masai giraffes in the late 1990s (East, 1999, p. 95), with only 2,530 individuals in protected areas. Surveys conducted in Kenya in 2010 and compiled by the 18

GCF in 2013 estimated that fewer than 8,000 individuals remain, primarily in the Masai Mara Ecosystem, Tsavo and Chyulu National Parks and surrounds, and the Amboseli Ecosystem (Marais et al., 2013, p. 9 (Kenya)). In the Masai Mara National Park and surrounding ranches on the Tanzanian border, several estimates show steep declines in Masai giraffe populations. Ottichilo et al. (2000, p. 206) found a 79% decline in the Masai giraffe population based on aerial survey data from 1977 to 1997. Ogutu et al. (2011, p. 4, supporting documentation) found the Masai giraffe population declined from an estimated 6,678 individuals in 1977 to 1,140 individuals in 2009, likely due to widespread illegal hunting. In Amboseli National Park and surrounding ranches, similar losses have occurred, but populations have recovered modestly from devastating droughts in the late 2000s (Okello et al., 2015, p. 171). In Tanzania, East (1999, p. 95) estimated that in the 1990s, there were 28,860 Masai giraffes throughout the country, mostly in protected areas. East noted population reductions in much of central and coastal Tanzania as well as significant losses in the Serengeti (East, 1999, p. 98). Serengeti National Park was estimated to contain 10,750 Masai giraffes in 1975-1977, dropping to 6,673 individuals in 1988-1991 (Strauss et al., 2015, p. 512). A more recent estimate from 2008-2010 found that only 3,520 Masai giraffes remained (ibid.). Strauss et al. (2015, p. 512) estimated that Masai giraffes saw a 67%-86% reduction in density in the Serengeti from 1977 to 2010. A 2015 aerial survey of the savannah on the Kenyan border estimated only 726 Masai giraffes in the Lake Natron area and 237 in the West Kilimanjaro area by averaging dry and wet season censuses from 2010 and 2013 (Okello et al., 2015, p. 166). In Rwanda, six Masai giraffes were introduced into Akagera National Park in 1986, and by 2012, expanded to about 100 giraffes (Marais et al., 2012, p. 2 (Rwanda)). In summary, Masai giraffes have experienced a 52% drop in population over the previous two to three decades, from an estimated 66,449 in the late 1970s to the current estimate of 31,611 individuals (Muller et al.,, Table 1). 19

H) Thornicroft s Giraffe (Giraffa camelopardalis thornicrofti) 1) Distribution Thornicroft s giraffes are entirely isolated to the Luangwa River Valley in northeastern Zambia, which includes South Luangwa National Park and surrounding areas (Du Raan et al., 2015, p. 2; Fennessy et al., 2013, p. 635-636). 2) Population Status Estimates regarding the size of the isolated population of Thornicroft s giraffe in Zambia have varied over time, but are consistently small. In 2015, the GCF estimated the population included 300 individuals in 1980 (Du Raan et al., 2015, p. 2; Berry & Bercovitch,, p. 1). East (1999, p. 95, 98) estimated that there were 450 Thornicroft s giraffes in Zambia in the early 1980s, but that the population grew to 1,160 by the 1990s. A 2002 aerial census of the area estimated the population at 236, with 197 in the South Luangwa National Park and the remaining in the surrounding Lupande Game Management Area (Du Raan et al., 2015, p. 6). In 2011, an aerial survey of the Luangwa Valley Ecosystem estimated 407 giraffes (Du Raan et al., 2015, p. 7). A more current estimate in 2013, utilizing systematic surveys, estimated 556 individuals in the Luangwa Valley (ibid.). The IUCN s assessment of G. c. thornicrofti estimated that the population is stable at about 600 individuals (Muller et al.,, p. 5). 20

I) Angolan Giraffe (Giraffa camelopardalis angolensis) 1) Distribution The Angolan giraffe subspecies (G. c. angolensis) historically ranged from southern Angola through Namibia and east into central Botswana (Du Raan et al.,, p. 3; East, 1999, p. 98-99). The Angolan giraffe has since been extirpated from Angola following years of civil unrest (Marais et al., 2013, p. 3 (Angola)). The subspecies occupies much of its former range in Namibia and Botswana (East, 1999, p. 98). In Namibia, the subspecies can be found in substantial numbers across northern Namibia in conservancies, national parks (e.g., Etosha National Park), and surrounding areas (Du Raan et al.,, p. 7-8). In Botswana, Angolan giraffes currently occupy the expansive Central Kalahari Game Reserve (Bock et al., 2014, p. 7). In addition, giraffe populations in northern Botswana (the Okavango Delta, Chobe National Park, and other protected lands), southern Botswana (Southern and Kweneng Districts), northeastern Namibia (Bwabwata National Park), western Zimbabwe, and southern Zambia (Sioma Ngwezi National Park) are considered Angolan giraffes but a recent genetic study suggests they may actually be South African giraffes (Bock et al., 2014, p. 7). The IUCN s assessment has provisionally retained this population status as Angolan giraffes for the purposes of its status review (Muller et al.,, p. 5). 2) Population Status In Namibia, Angolan giraffes in the northern national parks and their surrounds are increasing. In northwestern Namibia, a 2013 assessment estimated 2,039 Angolan giraffes across several conservancies, showing steady increases from estimates in 2002 (922 giraffes) and 2008 (1,269 giraffes) (Du Raan et al.,, p. 5). In north-central Namibia, most Angolan giraffes are found in Etosha National Park and the surrounding areas and a recent survey estimated 3,293 giraffes in the park and 1,743 around it (ibid., p. 8). This is a large increase from a 1995 estimate of 1,837 giraffes in Etosha National Park (ibid., p. 6). In northeastern Namibia, the GCF estimates that 21

about 1,000 giraffes occur across several national parks and surrounding regions (ibid., p. 8). Besides national park land and other government protected areas, much of Namibia s giraffe population resides on private game farms with an estimated 5,832 individuals, mostly in the Erongo, Kunene, and Otjozondjupa regions (ibid., p. 9). The GCF, in its assessment of giraffe in Namibia, estimated about 12,000 Angolan giraffes reside in the country, with about half on private land (ibid., p. 10). This is an increase from just one to two decades prior when estimates ranged from 5,000 to 10,415 in the country (ibid.). In Botswana, a 2004 country-wide census estimated about 11,700 Angolan giraffes, with Okavango Delta as the largest population (Tutchings & Fennessy, 2009, p. 4). But more recent surveys and anecdotal evidence indicate that populations of Angolan giraffes in Botswana are decreasing (ibid.). A 2012 country-wide survey estimated that 8,976 individuals inhabit the country (Statistics Botswana, 2015, p. 11). It is estimated that northern Botswana Angolan giraffe populations have dropped from more than 10,000 to fewer than 4,000 individuals in the last ten years (Bock et al., 2014, p. 2). Data from Statistics Botswana estimated only 5,440 Angolan giraffes remained in 2013 in the northernmost districts, which include the Okavango Delta and Chobe National Park (Statistics Botswana, 2015, p. 12). In central Botswana, in the Ghanzi district, which includes the Central Kalahari Game Reserve, a 2013 survey estimated only 923 Angolan giraffes (ibid., p. 14). In southern Botswana, aerial surveys reveal smaller Angolan giraffe populations in the Kweneng and Kgatleng districts (ibid., p. 18, 19). In Zambia, there is a small population of Angolan giraffes in Sioma Ngwezi National Park (Du Raan et al., 2015, p. 8; East, 1999, p. 98), although there is controversy over the population s subspecies (Bock et al., 2014, p. 7). A 2013 aerial survey estimated 232 Angolan giraffes in the park (Du Raan et al., 2015, p. 8). In Zimbabwe, Angolan giraffes occur in Hwange National Park and surrounding areas on the western edge of the country (Bock et al., 2014, p. 2; Crosmary et al., 2015, p. 198). This population is assumed to be Angolan giraffes but recent genetic analysis suggests it may belong to the South African subspecies (Bock et al., 2014, p. 7). The IUCN s assessment of G. c. angolensis estimated that the Angolan giraffe population has increased over the last four decades from about 15,000 individuals in the 1970s to the current estimate of over 30,000 giraffes (Muller et al.,, p. 5). This assessment includes the giraffe populations in central Botswana and north-central Namibia (estimated by the IUCN to be 5,000 in 1970 and 13,031 in ) ), as well as the giraffe populations in northern and southern Botswana, northeastern Namibia, western Zimbabwe, and southern Zambia (estimated by the IUCN to be 10,000 in 1970s and 17,551 in ) (ibid.). This latter population could in fact be South African giraffes according to a recent genetic study (Bock et al., 2014, p. 7) but are provisionally included as Angolan (Muller et al.,, p. 5). 22

J) South African Giraffe (Giraffa camelopardalis giraffa) 1) Distribution The historic distribution of the South African giraffe subspecies (G. c. giraffa) has been reported to follow the bushveld of northern South Africa east into southern Zimbabwe and southwestern Mozambique (East, 1999, p. 98-99). Current distribution includes northeastern South Africa as well as southern Zimbabwe and Mozambique on the border of South Africa (ibid., p. 99; Marias et al., 2013, p. 3 (Mozambique)). South African giraffes have also been introduced into Angola s Kissama National Park (Marais et al., 2013, p. 3 (Angola)). In addition, recent studies have indicated that giraffe populations in northern Botswana (the Okavango Delta, Chobe National Park, and other protected lands), southern Botswana, northeastern Namibia (Bwabwata National Park), western Zimbabwe, and southern Zambia (Sioma Ngwezi National Park) could be South African giraffes instead of Angolan giraffes, as previously described (Bock et al., 2014, p. 7). However, these populations will be considered to be Angolan giraffes until more evidence is collected indicating otherwise (Muller et al.,, Table 1). Extralimital populations of South African giraffe exist in Zambia, South Africa, and Swaziland (Bercovitch & Deacon, 2015, p. 142; Du Raan et al., 2015, p. 8; Marais et al., 2013, p. 3 (Swaziland)). 2) Population Status Bercovitch and Deacon (2015, p. 142) estimated that as many as 30,000 South African giraffes occur in South Africa. This is a significant increase from East s estimate (1999, p. 95) that 7,880 giraffes occurred in South Africa in the 1990s following losses due to overhunting and expansion of agriculture. Most giraffes survived primarily in Kruger National Park (East, 1999, p. 99). Since then, giraffes have been reintroduced into private and protected areas throughout their 23

former range, as well as outside of their range, and populations have recovered (Bercovitch & Deacon, 2015, p. 142). In Angola, it estimated that about 20 South African giraffes resided in Kissama National Park in 2013 (Marais et al., 2013, p. 3 (Angola)). This population originates from four giraffes introduced in 2001 (ibid.). In Swaziland, there are about 209 South African giraffes in government-owned protected areas and private establishments (Marais et al., 2013, p. 3 (Swaziland)). All Swaziland giraffes are extralimital populations and were translocated (ibid.). Giraffes were extirpated from Mozambique by the early 1970s due to overexploitation and habitat destruction (Marias et al., 2013, p. 2 (Mozambique)). However, translocations of South African giraffes from South Africa to Mozambique s Limpopo National Park and Maputo Special Reserve have helped reestablish small populations, with 116 giraffes in Limpopo National Park and 23 giraffes in Maputo Special Reserve (ibid., p. 3). The GCF s 2013 assessment of Mozambique giraffe populations estimates that there are 146 South African giraffes in the country (ibid.). In Zimbabwe, South African giraffes historically occurred throughout the southern part of the country, and continue to persist in private and protected areas in the southeastern Lowveld, primarily in Gonarezhou National Park where a small population remains (East, 1999, p. 99). The IUCN s assessment of G. c. giraffa estimated that the South African giraffe population has increased over the last three decades from about 8,000 individuals in the late 1970s to the current estimate of 21,387 individuals (Muller et al.,, p. 5). This assessment does not include the giraffe populations (estimated by the IUCN to be 10,000 in 1970s and 17,551 in ) in northern and southern Botswana, northeastern Namibia, western Zimbabwe, and southern Zambia, which are provisionally assumed to be Angolan giraffe, but could be South African according to a recent genetic study (Bock et al., 2014, p. 7). V) Threats Under the ESA, the Service is required to list a species as Endangered if it is in danger of extinction throughout all or a significant portion of its range or as Threatened if it is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range based upon one or more threats or factors. 16 U.S.C. 1532. There are five statutory listing factors that the Service must analyze for the species: (A) The present or threatened destruction, modification, or curtailment of its habitat or range; (B) Overutilization for commercial, recreational, scientific, or educational purposes; (C) Disease or predation; (D) The inadequacy of existing regulatory mechanisms; and (E) Other natural or manmade factors affecting its continued existence. 24

Id. 1533(a)(1)(A)-(E); 50 C.F.R. 424.11(c)(1)-(5). Based upon an analysis of these factors, all Giraffa camelopardalis should be protected as an endangered species under the ESA. 16 U.S.C. 1533(a)(1). Alternatively, the Service could list all giraffes at the subspecies or distinct population segment level as either threatened or endangered. A) Present or Threatened Destruction, Modification, or Curtailment of its Habitat or Range Habitat loss and fragmentation are one of the primary causes of giraffe population decline (Fennessy, 2004, p. 12; Muller et al.,, p. 1, 6). Indeed, giraffes have experienced severe habitat loss and fragmentation as a result of increased human settlement; expansion of agricultural activities; conversion of land to industrial plantations (e.g., sugarcane); the uncontrolled harvesting of timber and wood for various uses, including firewood, logging, and charcoal production for both personal and commercial purposes; and poor land use planning (Muller et al., p. 6; Okello et al., 2015, p. 170). This situation is exacerbated by the fact that people living in and near giraffe habitat are typically poor and compete with giraffes for resources like trees and shrubs (Marais et al., 2013, p. 1 (Cameroon); Marais et al., 2013, p. 2 (Swaziland)). Expansive habitat is a prerequisite for healthy giraffe populations, given their relatively large home ranges which average between 68 km² and 514 km² and their seasonal migration patterns (Shorrocks,, p. 148). However, largely as a result of habitat loss and degradation, the giraffe s range has contracted significantly over the past century (Dagg, 1971, p. 1; Fennessy, 2004, p. 14; Skinner & Smithers, 1990, p. 204-206). This has resulted in geographical isolation of local populations and some herds surviving at the edge of the species preferred range (Fennessy, 2004, p. 1). West African giraffes once ranged from Senegal to Lake Chad, but now only exist in approximately 15,000 km² in southwestern Niger (Fennessy & Brown, 2010, p. 2). Habitat loss and fragmentation have contributed to the West African giraffe s range contraction and subsequent population loss (Marais et al., 2014, p. 1 (Niger)). Kordofan giraffes, which once ranged from northern Cameroon through central and southern Chad, CAR, South Sudan, and northern DRC, now have limited habitat (East, 1999, p. 96-97). In Chad, Kordofan giraffes are losing habitat to cultivation and cattle grazing (Marais et al., 2014, p. 2 (Chad)). Increasing human development, agriculture, cattle grazing, and logging are contributing to Kordofan giraffe population declines in Cameroon (Marais et al., 2013, p.1-2 (Cameroon)). In South Sudan, giraffe habitat is lost to farming, logging, and human infrastructure and development (Marais et al., 2012, p. 2 (DRC)). 4 Nubian giraffes historically occurred in southern and northeastern Sudan and through Ethiopia s western and southern lowlands to Eritrea s southwestern savannas, but are currently only found 4 Giraffe in South Sudan may be Kordofan giraffe or Nubian giraffe (Marais et al., 2012, p. 4 (South Sudan)). 25

in Ethiopia and South Sudan (East, 1999, p. 97). In South Sudan, giraffe habitat is lost to farming, logging, and human infrastructure and development (Marais et al., 2012, p. 2 (DRC)). In Ethiopia, giraffe habitat is limited due to dense human populations and related fragmentation and loss of habitat (Marais et al., 2013, p. 1-2) (Ethiopia)). Reticulated giraffes once ranged from the southern lowlands of Ethiopia and Somalia, sweeping south into northern Kenya, bounded by the Tana River to the south, but now are only found in northern Kenya and southern Ethiopia (East, 1999, p. 97). In Kenya, reticulated giraffes are losing habitat and migration corridors due to expanding human settlements and farmlands, as well as wood cutting, and are now largely confined to protected areas (Marais et al., 2013, p. 3 (Kenya)). The world s only population of Thornicroft s giraffe resides in Zambia s Luangwa Valley, where habitat available to support wildlife is shrinking due to increased settlements, cultivation, traditional land claims, and uncoordinated planning by government departments (Du Raan et al., 2015, p. 3). Historically, the Rothschild s giraffe was widespread, found in Uganda, southern Sudan, and across western Kenya (Okello et al., 2015, p. 160). However, it has been exterminated from most of its former range, with only a few small and fragmented populations in Uganda and Kenya (ibid.). Masai giraffes, which exist primarily outside of government-protected areas, have also been eliminated in most of their former range over the last century, primarily due to anthropogenic activities (Marais et al., 2013, p. 2 (Kenya)). Changes in land use from crop farming, urbanization, and logging have led to range-wide habitat fragmentation which prevents giraffe dispersal (ibid.). Increasing human populations and related habitat loss are also a concern for Angolan and South African giraffes (Du Raan et al.,, p. 1; Marais et al., 2013, p. 1 (Mozambique)). Even Africa s national parks and sanctuaries which were historically occupied by giraffes have experienced severe habitat destruction impacting giraffes, mainly due to the lack of effective park management and law enforcement (Marais et al., 2013, p. 2 (Cameroon)). For example, in Angola the construction of two national roads through Kassima National Park has resulted in habitat fragmentation, shrimp farming, human encroachment, cultivation, oil production, livestock grazing, and charcoal production (Marais et al., 2013, p. 2-3 (Angola)). Most protected areas in Mozambique were invaded and occupied by local people from the surrounding areas during the Mozambican civil war (1977-1992), significantly reducing the country s biodiversity (Marais et al., 2013, p. 2 (Mozambique)). Following the Rwandan Civil War, Tanzanian and Ugandan refugees settled in much of Rwanda s Akagera National Park, negatively impacting wildlife (Marais et al., 2012, p. 1 (Rwanda)). Ethiopia, Cameroon, Somalia, and other giraffe range countries have experienced similar situations (Marais et al., 2013, p. 2 (Cameroon); Marais et al., 2013, p. 1-2 (Ethiopia); Marais et al., 2013, p. 1 (Somalia)). 26

As African countries continue to modernize, rapid population growth, infrastructure development, urbanization, agricultural development, deforestation, and other such activities will likely continue to escalate and negatively impact giraffes and their habitat (UNEP, 2013, p. 3, 10, 17). B) Overutilization for Commercial, Recreational, Scientific, or Educational Purposes 1) International Trade for Commercial, Recreational, or Scientific Purposes As giraffes are not listed on the Appendices of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), a valuable source of information on the utilization of giraffes for commercial, recreational, or scientific purposes is the U.S. Law Enforcement Management Information System (LEMIS) trade database. The database contains import and export data compiled from U.S. Fish and Wildlife forms and Customs and Border Patrol reports, which are accumulated into an electronic database that is available to the public via Freedom of Information Act (FOIA) request. This database can be used to determine the level of legal international trade to and from the U.S., as well as the types and sources of giraffes and their parts that are involved in trade. International trade as recorded in the LEMIS database includes commercial trade as well as trade associated with breeding, circus or travelling exhibition, education, enforcement, trophy hunting, medicinal use, personal use, reintroduction to the wild, scientific research, and zoological exhibition. By examining the documented purposes of trade, the LEMIS database can be used to evaluate the reasons behind the movement of giraffes and their parts to and from the U.S. The database also includes the source of giraffes and their parts in international trade, whether captive-bred, captive-born, illegal, ranch-raised, or wild. However, the LEMIS database does not contain information on total global trade in giraffe, total exports from range countries, or domestic use of giraffes or their parts for commercial, recreational, or scientific purposes; nor does it account for poaching and illegal trade, except where illicit international trade has resulted in a seizure by U.S. enforcement authorities. As the species is not listed on the CITES Appendices, this means that the volume of global trade in giraffes is unknown, but it is likely many times greater than the volume of U.S. trade presented in this petition. Giraffes are over-utilized for commercial and recreational purposes. The original analysis presented in this petition shows that between 2006 and 2015 (the most recent decade for which complete data are available), 39,516 giraffe specimens (giraffes, dead or alive, and their parts and derivatives) were imported to the U.S. for all purposes (Annex A, Table 1), the equivalent of at a bare minimum at least 3,751 giraffes. This figure was derived by adding the figures for three types of specimens that likely represent one giraffe each: bodies, live, and trophies. After giraffe are hunted, their skin is usually removed in sections, leaving the skull, other bones, and body parts. Therefore in this analysis, the body or trophy is used to represent a giraffe not the skull, skeleton, skin, or bones. However, because the majority of giraffe specimens in trade are giraffe parts (e.g., bone carvings, bones, skin pieces) and we are unable to determine how many giraffes these pieces represent, 3,751 is a very conservative estimate and the number of giraffes actually imported is likely much higher. 27

The most commonly-traded items were bone carvings (21,402), bones (4,789), trophies (3,744), skin pieces (3,008), bone pieces (1,903), skins (855), and jewelry (825) (see Table 2 below). Other giraffe specimens in trade include shoes (528), hair (501), small leather products (366), feet (339), large leather products (325), horn (ossicone) carvings (201), and smaller numbers of skulls, hair products, specimens, tails, skeletons, rugs, shell products, carapaces, trim, wood products (e.g. furniture), plates, genitalia, horns (ossicones), live animals, bodies, teeth, eggshells (e.g. ostrich egg products with giraffe hair affixed), ears, legs, and unspecified products (see Table 2 below). U.S. imports of giraffes reported as bodies, trophies, and live animals (categories for which each specimen represents one individual animal) for the period of 2006 to 2015 total 3,751, including imports of 3 bodies, 4 live giraffes, and 3,744 trophies (see Table 2 below). Table 2. Total U.S. Giraffe Imports, 2006-2015, all sources and all purposes. Wildlife Description 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 TOTALS Bone Carvings 2,933 4,194 1,641 2,735 1,736 233 790 1,418 1,495 4,227 21,402 Bodies 0 0 1 1 0 0 0 1 0 0 3 Bones 167 65 487 345 77 1403 350 434 775 686 4,789 Bone Pieces 1,691 2 15 9 10 2 37 7 76 54 1,903 Carapaces 38 0 0 0 0 0 0 1 0 0 39 Ears 0 0 0 0 0 0 0 0 1 0 1 Eggshells 0 2 0 0 0 0 0 0 0 0 2 Feet 18 9 22 37 45 29 69 58 23 29 339 Genitalia 0 0 2 1 0 0 0 0 2 1 6 Hair 400 2 5 1 0 1 0 81 0 11 501 Hair Products 10 0 0 2 2 0 1 0 3 100 118 Horn Carvings 0 0 0 0 0 3 0 63 48 87 201 Horns 0 0 0 0 0 2 3 0 0 0 5 Jewelry 53 66 670 0 10 0 5 9 5 7 825 Leather Products Large 2 3 6 18 32 11 11 58 76 108 325 Leather Products Small 5 4 3 1 1 3 42 147 58 102 366 Legs 0 0 0 0 0 0 0 1 0 0 1 Live 0 0 0 0 3 0 0 1 0 0 4 Plates 0 0 0 0 0 0 0 3 2 3 8 Rug 15 6 15 5 6 0 2 8 1 5 63 Shell Product 0 0 0 0 0 0 0 0 50 0 50 Shoes 0 0 0 0 0 0 0 2 8 518 528 Skeletons 0 0 0 0 0 0 0 0 0 64 64 Skins 16 22 115 18 307 9 18 22 163 165 855 Skin Pieces 50 310 85 133 34 245 62 704 465 920 3,008 Skulls 18 2 14 12 32 29 6 6 4 27 150 28

Wildlife Description 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 TOTALS Specimens 1 0 0 19 0 0 50 6 0 25 101 Tails 1 0 1 15 7 6 18 7 5 5 65 Teeth 0 0 0 0 1 0 0 0 0 2 3 Trim 0 2 3 4 0 9 0 1 0 2 21 Trophies 425 372 339 405 280 328 342 408 386 459 3,744 Unspecified 10 0 0 2 1 0 0 1 2 0 16 Wood Products 0 0 0 6 0 1 0 3 0 0 10 TOTAL 5,853 5,061 3,424 3,769 2,584 2,314 1,806 3,450 3,648 7,607 39,516 Source: LEMIS data obtained from United States Fish and Wildlife Service through FOIA requests between 2006 and 2015, filtered for imports of Giraffa camelopardalis. Of this trade from all sources, 39,397 giraffe specimens, reported as being from a wild source the equivalent of at least 3,740 giraffes (adding bodies, live, and trophies) were traded internationally for all purposes (Annex A, Table 2). Wild-sourced specimens accounted for 99.7% of specimens in trade (39,397 of 39,516). The top countries exporting wild giraffes and their parts were South Africa (31,245 specimens representing at least 2,207 giraffes) (see Annex A, Table 25), Zimbabwe (5,249 specimens representing at least 971 giraffes) (see Annex A, Table 28), Tanzania (692 specimens representing at least 1 giraffe) (see Annex A, Table 26), and Namibia (685 specimens representing at least 521 giraffes) (see Annex A, Table 23). This means that South African giraffes, Angolan giraffes, and Masai giraffes are likely most frequently in trade. From 2006 through 2015, giraffes and their parts from the following additional sources were imported into the U.S.: 30 captive-bred 5 giraffes and their parts, the equivalent of at least 4 giraffes, including 1 live, 3 trophies, 3 bones, 1 bone carving, 1 hair, 4 large leather products, 3 small leather products, 1 rug, 8 shoes, 6 skins, 1 skull, and 1 trim (Annex A, Table 3). 5 captive-born 6 giraffes and their parts, the equivalent of at least 4 giraffes, including 3 live, 1 trophy, and 1 bone carving (Annex A, Table 4). 28 ranched 7 giraffes and their parts, the equivalent of at least 3 giraffes, including 5 bone carvings, 12 bones, 5 hairs, 1 horn carving, 2 horns, 5 skulls, and 3 trophies (Annex A, Table 5). 16 unknown source 8 giraffes and their parts, the equivalent of >1 giraffe, including 1 bone carving, 12 bone pieces, 1 large leather product, and 1 unspecified product (Annex A, Table 6). 5 LEMIS Source code C. 6 LEMIS Source code F. 7 LEMIS Source code R. 8 LEMIS Source code U. 29

In addition, from 2006 through 2015, the U.S. exported a total of 1,204 giraffe specimens, representing 93 individual giraffes (65 live animals and 28 trophies). Other specimens exported included 51 bone carvings, 1 bone, 33 bone pieces, 6 feet, 1 hair, 700 pieces of jewelry, 4 large leather products, 4 small leather products, 1 plate, 1 rug, 134 shoes, 3 skeletons, 151 skins, 12 skin pieces, and 7 skulls (see Table 3 below). Table 3. Total U.S. Giraffe Exports, 2006-2015, all sources and all purposes. Wildlife Description 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 TOTALS Bone Carvings 0 21 0 0 0 0 0 1 8 21 51 Bones 0 0 0 1 0 0 0 0 0 0 1 Bone Pieces 0 0 0 0 0 0 0 8 7 18 33 Feet 0 0 0 4 0 1 0 0 0 1 6 Hair 0 0 0 0 0 0 1 0 0 0 1 Jewelry 0 0 700 0 0 0 0 0 0 0 700 Leather Products, Large 0 0 0 0 0 0 0 0 1 3 4 Leather Products, Small 0 0 0 0 4 0 0 0 0 0 4 Live 9 9 1 0 9 4 4 4 13 12 65 Plates 0 0 0 1 0 0 0 0 0 0 1 Rugs 0 0 0 1 0 0 0 0 0 0 1 Shoes 0 0 0 0 52 8 40 12 22 0 134 Skeletons 0 0 1 0 2 0 0 0 0 0 3 Skins 2 0 0 0 0 1 1 1 122 23 150 Skin Pieces 0 0 0 0 0 0 0 0 11 1 12 Skulls 0 0 0 3 0 0 0 1 2 1 7 Trophies 1 4 2 2 1 9 2 3 1 3 28 TOTAL 12 34 704 12 68 23 48 30 187 83 1,201 Source: LEMIS data obtained from United States Fish and Wildlife Service through FOIA requests between 2006 and 2015, filtered for exports of Giraffa camelopardalis from all sources and for all purposes. Of these, 1,131 were wild-sourced, representing at least 26 individual giraffes, including 26 trophies. Other giraffe products exported included bone carvings (4), bones (1), bone pieces (33), feet (6), jewelry (700), large leather products (4), small leather products (4), plates (1), shoes (134), skins (150), skin pieces (12), and skulls (7) (Annex A, Table 7). From 2006 through 2015, giraffes and their parts from the following additional sources were exported from the U.S.: 59 captive-bred giraffes and their parts, the equivalent of at least 55 giraffes, including 55 live animals, 3 skeletons, and 1 hair (Annex A, Table 8). 8 captive-born giraffes and their parts, the equivalent of at least 8 giraffes, including 7 live and 1 trophy (Annex A, Table 9). 30

3 ranched giraffes, as live animals (Annex A, Table 10). a) Trade for Commercial Purposes Giraffa camelopardalis is not listed on the CITES Appendices and thus international trade is not monitored and traceable like trade in CITES-listed species. However, from the LEMIS data it is evident that most of the trade in giraffes to and from the U.S. is for commercial purposes. i) U.S. Imports of Giraffes and Their Products for Commercial Purposes From 2006 to 2015, at least 33,321 giraffe specimens, the equivalent of at least 157 individual giraffes, were imported into the U.S. for commercial purposes (see Table 4 below). Commercial giraffe imports represented 84.3% of the total imports during this period. The vast majority of these specimens were bone carvings (20,885), bones (3,768), skin pieces (2,820), and bone pieces (1,857). Other commercial imports included jewelry (766), skins (715), shoes (526), hair (487), small leather products (314), horn carvings (200), trophies (154), and smaller amounts of other parts and products. Table 4. Total U.S. Giraffe Imports, 2006-2015, all sources, commercial purposes. Wildlife Description 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 TOTAL Bone Carvings 2,908 4,150 1,611 2,707 1,699 189 734 1,340 1,418 4,129 20,885 Bones 142 54 474 171 38 1,359 323 348 223 636 3,768 Bone Pieces 1,678 0 0 5 9 0 35 3 73 54 1,857 Carapaces 0 0 35 0 0 0 0 0 0 0 35 Feet 0 0 12 29 25 5 40 6 0 0 117 Hair 400 2 4 0 0 0 0 81 0 0 487 Hair Products 0 0 0 0 0 0 0 0 0 100 100 Horn Carvings 0 0 0 0 0 3 0 63 47 87 200 Horns 0 0 0 0 0 2 3 0 0 0 5 Jewelry 50 46 670 0 0 0 0 0 0 0 766 Leather Products Large 0 0 0 0 0 0 4 21 37 76 138 Leather Products Small 4 4 0 0 0 0 41 137 44 84 314 Live 0 0 0 0 3 0 0 0 0 0 3 Rug 15 5 11 2 5 0 0 0 0 2 40 Shell Product 0 0 0 0 0 0 0 0 50 0 50 Shoes 0 0 0 0 0 0 0 0 8 518 526 Skeletons 0 0 0 0 0 0 0 0 0 64 64 Skins 7 12 85 13 304 2 8 9 142 133 715 Skin Pieces 39 296 69 91 21 241 58 678 456 871 2,820 31

Skulls 10 0 12 11 29 26 0 3 1 17 109 Specimens 0 0 0 0 0 0 50 0 0 0 50 Tails 0 0 0 6 0 0 0 0 0 0 6 Teeth 0 0 0 0 1 0 0 0 0 0 1 Trim 0 0 0 0 0 0 0 1 0 0 1 Trophies 125 0 0 2 1 3 17 2 3 1 154 Unspecified 10 0 0 0 0 0 0 0 0 0 10 TOTAL 5,388 4,569 2,983 3,037 2,135 1,830 1,313 2,692 2,502 6,772 33,221 Source: LEMIS data obtained from United States Fish and Wildlife Service through FOIA requests between 2006 and 2015, filtered for imports of Giraffa camelopardalis for commercial purposes from all sources. Upon inspection of the Service s records, some giraffe products were seized by the U.S. and reported as such in the LEMIS database (Annex A, Table 11). For example, from 2006-2015, a total of 70 giraffe products imported into the U.S. for commercial purposes were seized by U.S. authorities. These include bone carvings (9), bones (4), jewelry (50), small leather products (2), and trophies (5). According to LEMIS data, significant commercial trade in giraffes and their parts occurred between 2006 and 2008, after which trade decreased until 2010. Since 2011, however, there has been a dramatic increase in U.S. imports of giraffes and their products for commercial purposes (see Figure 1 below). The amount of bone carvings, shoes, and skin pieces imported for commercial purposes has increased markedly over the last five years (see Figure 1 below), with concurrent increases in other products such as skins, shoes, leather products, and horn (ossicone) carvings for commercial purposes (see Table 4 above). Figure 1. U.S. Imports of Giraffes for Commercial Purposes, 2006-2015, Bone Carvings, Shoes, and Skin Pieces 4500 4000 Number of Products Imported 3500 3000 2500 2000 1500 1000 500 Bone Carvings Shoes Skin Pieces 0 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Source: LEMIS data obtained from United States Fish and Wildlife Service through FOIA requests between 2006 and 2015, filtered for imports of Giraffa camelopardalis for commercial purposes from all sources. 32

ii) U.S. Exports of Giraffes and Their Products for Commercial Purposes For commercial purposes, the U.S. exported 1,117 giraffes and their products between 2006 and 2015 for commercial purposes, representing at least 52 individual giraffes, including 41 live animals and 11 trophies. The commercial exports represent 98.8% of the total exports of giraffes and their products during this period. Additional commercial exports of giraffe products included bone carvings (30), bone pieces (25), jewelry (700), large leather products (4), small leather products (4), shoes (134), skeletons (3), skins (150), skin pieces (11) and skulls (4) (see Table 5 below). Table 5. Total U.S. Giraffe Exports, 2006-2015, all sources, commercial purposes. Wildlife Description 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 TOTAL Bone Carvings 0 21 0 0 0 0 0 1 7 8 37 Bones 0 0 0 0 0 0 0 0 0 0 0 Bone Pieces 0 0 0 0 0 0 0 0 0 18 18 Jewelry 0 0 700 0 0 0 0 0 0 0 700 Leather Products Large 0 0 0 0 0 0 0 0 1 3 4 Leather Products Small 0 0 0 0 4 0 0 0 0 0 4 Live 5 8 1 0 9 4 2 0 8 4 41 Shoes 0 0 0 0 52 8 40 12 22 0 134 Skeletons 0 0 1 0 2 0 0 0 0 0 3 Skins 2 0 0 0 0 1 1 1 122 23 150 Skin Pieces 0 0 0 0 0 0 0 0 11 0 11 Skulls 0 0 0 1 0 0 0 1 2 0 4 Trophies 0 1 1 1 1 6 0 0 1 0 11 TOTAL 7 30 703 2 68 19 43 15 174 56 1,117 Source: LEMIS data obtained from United States Fish and Wildlife Service through FOIA requests between 2006 and 2015, filtered for exports of Giraffa camelopardalis for commercial purposes from all sources. Local and international trade in giraffe and giraffe products in certain countries such as Namibia pose a risk to giraffes as increased numbers of carved giraffe bones have recently been observed at local tourist markets (du Raan et al.,, p. 2). The data presented above show that not only does the U.S. import a significant amount of giraffes and their products for commercial purposes representing potential or known overutilization in range States but also that there is an ongoing increasing trend in commercial imports of giraffes and their products that, in light of population trends (Muller et al.,, p. 4-5), threatens to further exacerbate decline in an already vulnerable species. b) Trade for Recreational Purposes A significant number of giraffes in trade are traded for hunting trophy purposes and giraffes are clearly over-utilized for this purpose. 33

i) U.S. Imports of Giraffes and Their Products for Recreational Purposes From 2006 to 2015, 5,044 giraffe specimens, representing at least 3,563 individual giraffes, were imported into the U.S. for hunting trophy purposes; including 3,561 trophies, 1 body, and 1 live animal. The most common type of specimen imported for hunting trophy purposes were trophies (3,561), followed by bones (813) and bone carvings (174) (Annex A, Table 12). The top exporters of giraffe specimens for hunting trophy purposes were South Africa (3,065 or 60.8%), Zimbabwe (1,346 or 26.7%), and Namibia (575 or 11.4%) (Annex A, Table 13). Together these three countries account for 98.9% of giraffe specimens imported to the U.S. for hunting trophy purposes. Since 2010 there has been a marked increase in the number of giraffe trophies imported to the U.S., peaking in 2015, when 457 trophies were imported (see Figure 2 below). Since 2006, the U.S. has imported over 300 giraffe trophies per year, with the single exception of 2010 (when trophy imports totaled 276), indicating that the U.S. continues to be a major importer of giraffe hunting trophies in this decade. Figure 2: U.S. Imports of Giraffe Trophies for Hunting Trophy Purposes, 2006-2015 500 450 Number of Trophies Imported 400 350 300 250 200 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Source: LEMIS data obtained from United States Fish and Wildlife Service through FOIA requests between 2006 and 2015. ii) U.S. Exports of Giraffes and Their Products for Recreational Purposes From 2006 to 2015, 26 giraffe specimens, representing at least 11 individual giraffes, were exported for hunting trophy purposes. The most common type of specimen exported for hunting trophy purposes were trophies (11), followed by feet (5), and bone carvings (4) (Annex A, Table 14). 34

c) Trade for Scientific Purposes From 2006 through 2015, 53 giraffe parts and products were imported into the U.S. for scientific purposes (Annex A, Table 15), including hair (6), specimens (45) and teeth (2), all of which were wild-sourced. d) Trade for Other Purposes From 2006 through 2015, giraffes and their parts and products were imported into the U.S. for other purposes, including: 1 bone for educational 9 purposes. 1,195 giraffe parts and products for personal 10 purposes including 29 giraffe trophies. South Africa is, by far, the country with the most number of giraffe trophies exported to the U.S. for personal purposes, with 15 exported to the US, comprising 51.7% of all such imports (Annex A, Table 16). 1 body, 1 foot, 1 hair, and 6 specimens for circus or traveling exhibition 11 purposes (Annex A, Table 17). 1 live giraffe for zoo 12 purposes. From 2006 through 2015, giraffes and their parts and products were exported from the U.S. for other purposes, including: 2 giraffe trophies for educational purposes. 30 giraffe parts and products for personal purposes, including 17 bone carvings, 8 bone pieces, 1 skin piece, and 4 trophies. All of these exports were wild-sourced (Annex A, Table 18). 1 foot and 1 product containing giraffe hair for circus or traveling exhibition purposes. 24 live giraffes for zoo purposes (Annex A, Table 19). e) International Trade to the U.S. from Giraffe Range States This section provides details about the export of giraffes and their parts and products to the U.S. by giraffe range States from 2006 through 2015. The following range States did not export giraffes or their parts or products during this period: Angola, Cameroon, Central African Republic, Chad, The Democratic Republic of Congo, Mozambique, Niger, Somalia, South 9 LEMIS purpose code E. 10 LEMIS purpose code P. 11 LEMIS purpose code Q. 12 LEMIS purpose code Z. 35

Sudan, and Uganda. Between 2006 and, eight giraffe range States exported giraffes and their parts and products to the U.S.; the seven countries that exported giraffe bodies, live animals, or trophies (which are each equal to one giraffe) are listed in Table 6 below. Table 6. Range States Exporting Giraffe and their Products to the U.S., 2005-. Country of Export Individual Giraffes Exported (bodies, live, trophies) South Africa 2,212 59% Zimbabwe 971 26% Namibia 522 14% Botswana 21 1% Zambia 7 <1% Tanzania 1 <1% Ethiopia 1 <1% TOTAL 3,735 100% % of U.S. Imports of Giraffes and their products (rounded to nearest whole percent) The following section details exports to the U.S. from giraffe range States, based on U.S. import records. i) Botswana Botswana exported a total of 24 giraffe products, equivalent to at least 21 individuals, between 2006 and 2015, including 21 trophies (Annex A, Table 20). This amount comprises approximately 1% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (22 of 3,735). In addition, 1 skin and 2 pieces of jewelry were exported to the U.S. during this period. All of these were wild-sourced and imported into the U.S. for hunting trophy purposes. ii) Ethiopia Ethiopia exported 1 giraffe trophy between 2006 and 2015 (Annex A, Table 21). This amount comprises less than 1% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (1 of 3,735). This trophy was wild-sourced and imported into the U.S. for hunting trophy purposes. iii) Kenya Kenya exported giraffe products equivalent to less than one individual between 2006 and 2015, including 3 pieces of jewelry and 125 bone carvings (Annex A, Table 22). This amount comprises 0% of the total U.S. imports of giraffe and their products equivalent to individual animals during that period (0 of 3,735). The estimate is zero because one cannot estimate the number of individual giraffes represented from jewelry and bone carvings. All of these were wild-sourced and the pieces of jewelry were imported into the U.S. for personal purposes, while the bone carvings were imported for commercial purposes. 36

iv) Namibia Namibia exported a total of 685 giraffe products, equivalent to at least 522 individuals, between 2006 and 2015, including 522 trophies (Annex A, Table 23). This amount comprises approximately 14% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (522 of 3,735). For hunting trophy purposes, 9 bone carvings, 9 bones, 14 feet, 3 genitalia, 1 leg, 12 skins, 2 skin pieces, 2 skulls, 3 tails, 1 unspecified product, and one wood product were imported into the U.S. from Namibia between 2006 and 2015. All of these were wild-sourced. For personal purposes, 17 bone carvings, 7 bones, 4 bone pieces, 6 feet, 5 hair products, 1 small leather product, 3 skins, 2 skin pieces, and 1 skull were imported. All of these were wildsourced. For scientific purposes, 19 specimens were imported into the U.S. from Namibia between 2006 and 2015. All of these were wild-sourced. For commercial purposes, 40 bones were imported into the U.S. from Namibia between 2006 and 2015. All of these were wildsourced. v) Nigeria Nigeria exported 1 giraffe product equivalent to one individual between 2006 and 2015, consisting of 1 wild-sourced giraffe skin for personal purposes (Annex A, Table 24). This amount comprises nearly 0% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (1 of 3,735). vi) South Africa South Africa exported 31,245 giraffe products, equivalent to at least 2,212 individuals, between 2006 and 2015, including 2,210 trophies and 2 bodies. This amount comprises approximately 59% of the total U.S. imports of giraffes and their products equivalent to 2,212 individual animals during that period (2,212 of 3,735). South Africa exported a total of 31,245 giraffe parts to the U.S. during this period (Annex A, Table 25). For educational purposes, 1 wild-sourced bone was exported from South Africa to the U.S. between 2006 and 2015. For hunting trophy purposes, 3 captive-bred giraffe trophies were exported from South Africa to the U.S. between 2006 and 2015. From wild-sourced giraffes, 137 bone carvings, 1 body, 613 bones, 3 bone pieces, 1 carapace, 1 ear, 71 feet, 2 genitalia, 6 hair products, 65 large leather products, 1 small leather product, 2 plates, 3 rugs, 68 skins, 15 skin pieces, 12 skulls, 3 tails, 2 trims, 2,049 trophies, and 1 unspecified product were exported from South Africa for hunting trophy purposes to the U.S. between 2006 and 2015. In addition, 2 trophies from ranched giraffes were exported from South Africa for hunting trophy purposes to the U.S. between 2006 and 2015. For personal purposes and from wild-sourced giraffes, 62 bone carvings, 1 body, 84 bones, 2 bone pieces, 3 carapaces, 2 eggshells, 79 feet, 1 genitalia, 1 hair, 2 hair products, 22 pieces of jewelry, 45 large leather products, 22 small leather products, 3 plates, 4 rugs, 7 skins, 41 skin 37

pieces, 2 skulls, 8 tails, 1 trim, 15 trophies, 2 unspecified products, and 3 wood products were exported from South Africa to the U.S. between 2006 and 2015. From captive-bred giraffes, 2 large leather products were imported from South Africa to the U.S. for personal purposes between 2006 and 2015. For scientific purposes, 1 wild-sourced specimen was exported from South Africa to the U.S. between 2006 and 2015. For commercial purposes and from captive-bred giraffes, 31 bone carvings, 3 bones, 2 large leather products, 3 small leather products, 4 skins and 1 trim were exported from South Africa to the U.S. between 2006 and 2015. From ranched giraffes, 1 horn carving, 1 horn and 12 bones were exported from South Africa to the U.S. between 2006 and 2015. From wild-sourced giraffes, 20,070 bone carvings, 3,677 bones, 1,844 bone pieces, 35 carapaces, 117 feet, 56 hairs, 100 hair products, 199 horn carvings, 3 horns, 46 pieces of jewelry, 49 large leather products, 146 small leather products, 40 rugs, 64 skeletons, 87 skins, 640 skin pieces, 105 skulls, 50 specimens, 50 shell products, 6 tails, 1 tooth, 141 trophies, and 10 unspecified products were exported from South Africa to the U.S. between 2006 and 2015. From unknown sources, 12 bone pieces were exported from South Africa for commercial purposes to the U.S. between 2006 and 2015. vii) Tanzania Tanzania exported 692 giraffe products, equivalent to at least one individual, between 2006 and 2015, including 1 wild-sourced trophy for hunting trophy purposes (Annex A, Table 26). This amount comprises <1% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (1 of 3,735). For personal purposes, 1 hair product and 690 pieces of jewelry were exported from Tanzania to the U.S. between 2006 and 2015. viii) Zambia Zambia exported 41 giraffe products equivalent to at least seven individuals between 2006 and 2015, including 7 wild-sourced trophies exported for hunting trophy purposes (Annex A, Table 27). This amount comprises less than 1% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (7 of 3,735). For personal purposes, 1 wild-sourced bone carving was exported from Zambia to the U.S. between 2006 and 2015. For scientific purposes, 6 hairs, 2 teeth, and 25 specimens from wildsourced giraffes were exported from Zambia to the U.S. between 2006 and 2015. ix) Zimbabwe Zimbabwe exported 5,429 giraffes and their products, equivalent to at least 971 individuals, between 2006 and 2015, including 971 wild-sourced trophies (Annex A, Table 28). This amount comprises 26% of the total U.S. imports of giraffes and their products equivalent to individual animals during that period (971 of 3,735). 38

For hunting trophy purposes from wild-sourced giraffes, 28 bone carvings, 185 bones, 3 bone pieces, 9 bones, 14 feet, 2 genitalia, 7 pieces of jewelry, 12 large leather products, 16 small leather product, 3 rugs, 32 skins, 66 skin pieces, 14 skulls, 3 tails, 5 trims, and 952 trophies were exported from Zimbabwe to the U.S. between 2006 and 2015. In addition, 2 trophies from ranched giraffes were exported from South Africa for hunting trophy purposes to the U.S. between 2006 and 2015. For personal purposes from wild-sourced giraffes, 97 bone carvings, 116 bones, 17 bone pieces, 37 feet, 5 pieces of jewelry, 61 large leather products, 12 small leather products, 3 plates, 11 rugs, 10 skins, 61 skin pieces, 6 skulls, 39 tails, 12 trims, 9 trophies, and 4 wood products were exported from Zimbabwe to the U.S. between 2006 and 2015. Therefore, as demonstrated in this section, the African giraffe is endangered by overutilization for commercial and recreational purposes, and the U.S. plays a major role in this unsustainable international trade. 2) Online Sales of Giraffe Products a) Methodology Between November 30, and December 21,, one researcher based in Washington, D.C., conducted an assessment of online sales of products made from giraffe parts (Annex B, Table 29). The online search was conducted in English and Russian 13 and was intended to capture a sample of products available for purchase. Due to restrictions in ability to search for products in additional languages and limited capacity, it is reasonable to assume the actual online trade in giraffe parts is far greater in volume and worth much more financially than what the research reveals. The product search was conducted using the Google search engine and the following English and Russian language search terms: giraffe hide (жираф шкура), giraffe skin (жираф кожа), giraffe knife (жираф нож), giraffe gun (жираф ружье), giraffe bone (жираф кость), authentic giraffe hide (натуральная шкура жирафа), giraffe skin purse (жираф сумка кожа), giraffe carpet (жираф ковер), giraffe skin genuine carpet (жираф шкура настоящий ковер), giraffe skin boots (жираф кожа сапоги), giraffe hair (жираф волосы). Furthermore, tailored searches for these same terms were also conducted separately on Amazon.com, Ebay.com, and Etsy.com. From each relevant search result, the researcher recorded the following information: item description, quantity offered, cost per item, website address, manufacturer title, seller title, seller address, country, and search date. b) Findings A total of 1,224 items made from giraffe parts were discovered for sale online during the research period. However, it must be noted that many websites did not indicate the quantity of 13 Russian was selected as the additional language because the individual conducting the research for this section speaks fluent Russian and therefore had the ability to analyze the findings. 39

items in stock, which means that the total number of items covered by the search is likely much higher. The following are the types of items found available for sale: skeleton parts (skulls, neck vertebrae, upper leg bones, lower leg bones, and shoulder blades); bone products (carvings, blocks, cylinders, earrings, rounds, scales, thumb studs, pen blanks, pistol grips); knives (bone handles); cutlery set (bone handles); hair products (bracelets, necklaces); taxidermy (bust, leg mount); skin products (hides, handbags, rugs, handgun cases, pillows, boots); and products such as tables and lamps made of other body parts. The most common type of objects offered for sale were scales (a piece of raw bone in the shape of a rectangle that is carved into knife handles) or giraffe bones that may be used to make knife handles, with 346 such items found. The second most common were raw bones (neck, skull, legs, etc.), with 159 such items found. The third most common objects offered for sale were knives featuring giraffe bone handles, with 132 found. The cost of these items ranged between $5 (one giraffe bone) and $7,635 (full giraffe taxidermy bust including shoulders, neck, and head) per item. The total cost of items found is not known because total stock quantities were unavailable and, therefore, the items found represent only a small sample of all giraffe products available for sale online. Products found were available for shipping from the U.S., South Africa, Namibia, Russia, Ukraine, India, and France. However, the scope of all countries that may offer giraffe products for sale may be limited by the language restrictions of the researcher conducting the online search and the fact the searches were limited to common search engines or point of sale websites (e.g., ebay). The largest country from which and in which giraffe products may be purchased online, according to our research, is the U.S.. The states in which giraffe product sellers operated included Florida, Georgia, Nevada, New York, North Carolina, Oklahoma, Pennsylvania, Tennessee, Texas, and Washington. Some of the online retailers include: Amazon ebay Etsy SafariWorks Taxidermy Sale 1stdibs.com Cavender's Genuine Exotic Skins and Hides African Crafts Market Knife Making Mercorne Mackrill Knives Texas Knifemaker's Supply Blade Gallery Ever After Guide Knives Ship Free Coast Ivory Knife Handles Camel Bone Knife Handles Atlantic Coral Enterprise, Inc. Sabatier Shop Natural Exotics African Game Industries Caspers Taxidermy Kelly Larson Sales Culpepper & Co. Knife Kits Asian Loft Loft Concept ArtWood of Africa Regmarkets Shkury Kovry Rezat.ru 40

The following are screenshots of some of the items found: Source: 1stdibs, Rare African Taxidermy Massive Tall Part Giraffe. 14 Source: SafariWorks, Taxidermy Sales, Giraffe Skin. 15 14 1stdibs, Rare African Taxidermy Massive Tall Part Giraffe, available at https://www.1stdibs.com/furniture/more-furniture-collectibles/taxidermy/rare-african-taxidermy-massivetall-part-giraffe/idf_3881812/?utm_content=control&gclid=cjwkeaiajvrbbrdxm_nrusw3q1qsjaazri1thsn_wmzwb UeuMnPTIDU63ut2kH24hSOgtJLTxGmwYxoCqrnw_wcB (last visited Jan. 6, 2017). 41

Source: Loft Concept, Natural Giraffe Skin. 16 Source: Amazon.com, Custom Made Damascus Steel Hunting Knife w/ Giraffe & Camel Bone Handle. 17 15 SafariWorks, Taxidermy Sales, Giraffe Skin, available at http://www.safariworkstaxidermysales.com/giraffe_skin_p/sw3177.htm (last visited Jan. 6, 2017). 16 Loft Concept, Natural Giraffe Skin, available at http://loft-concept.ru/catalog/hide-andrug/naturalnaya-shkura-zhirafa/ (last visited Jan. 6, 2017). 17 Amazon.com, Top Swords, Custom Made Damascus Steel Hunting Knife w/ Giraffe & Camel Bone Handle, available at https://www.amazon.com/custom-damascus-hunting-giraffe- Handle/dp/B010TR4Z2M?SubscriptionId=AKIAJO7E5OLQ67NVPFZA&ascsubtag=817452680-26- 123607149.1481923733&camp=2025&creative=165953&creativeASIN=B010TR4Z2M&linkCode=xm2 &tag=shopperz_origin2-20 (last visited Jan. 6, 2017). 42

Source: Rezat.ru, Arno Bernard Knives. 18 Source: Ebay.com, Worldwide Wildlife Products, 25 inch South African Giraffe Shoulder Blade bone taxidermy. 19 18 Rezat.ru, Arno Bernard Knives, available at http://rezat.ru/ref/rukmaterial/kost_zhirafa/ (last visited Jan. 6, 2017). 19 Ebay.com, Worldwide Wildlife Products, 25 inch South African Giraffe Shoulder Blade bone taxidermy, available at http://www.ebay.com/itm/25-inch-south-african-giraffe-shoulder-blade-bone- taxidermy-t-4807/371435596919?_trksid=p2047675.c100623.m- 1&_trkparms=aid%3D222007%26algo%3DSIC.MBE%26ao%3D1%26asc%3D38530%26meid%3D516 3f1d2bbf94d3c89486fcbca63ddd6%26pid%3D100623%26rk%3D2%26rkt%3D6%26sd%3D2014933428 51 (last visited Jan. 6, 2017). 43

Source: Jantz Supply, Super Natural - Giraffe Bone. 20 Source: African Game Industries, Giraffe Hide Skin Pillow. 21 20 Jantz Supply, Super Natural - Giraffe Bone, available at http://www.knifemaking.com/categorys/1165.htm (last visited Jan. 6, 2017). 21 African Game Industries, Giraffe Hide Skin Pillow, available at http://africangame.com/store/#!/giraffe-hide-skin-pillow/p/73750296 (last visited Jan. 6, 2017). 44

Source: African Game Industries, Giraffe & Buffalo Hide Handgun Case. 22 Source: Atlantic Coral Enterprise, Inc., Giraffe Bones Hand Picked Pricing. 23 22 African Game Industries, Giraffe & Buffalo Hide Handgun Case, available at http://africangame.com/store/#!/giraffe-&-buffalo-hide-handgun-case/p/73750303 (last visited Jan. 6, 2017). 23 Atlantic Coral Enterprise, Inc., Giraffe Bones Hand Picked Pricing, available at http://www.atlanticcoralenterprise.com/productcart/pc/viewcategories.asp?idcategory=697 (last visited Jan. 6, 2017). 45

Source: African Crafts Market, African Giraffe Skull. 24 3) Survey-Based Giraffe Parts Trade Data In a group of researchers used a questionnaire to survey giraffe experts in order to determine the types of giraffe products encountered in trade and any potential trends of trade (Khalil et al., ). There were 90 respondents from 18 countries in Africa and one in Europe, with most respondents located in Kenya, South Africa, Namibia, Tanzania, and Zimbabwe. According to the results, most survey responses referred to clothing and souvenir items made from giraffe parts. These items included jewelry, bracelets, skins, mounts, carved bone, tails, and purses (Khalil et al.,, p. 3). Another major product category referenced by the respondents was food, including sausages, dried meat, and bushmeat (ibid.). The final category included items used for medicinal purposes such as aphrodisiacs, headache cures, and magic potions (Khalil et al.,, p. 4). With respect to trends, most survey respondents said that trade was stable. Those who believed that the number of items available for trade decreased cited declining giraffe populations as one explanation. Those who believed that trade in giraffe parts was increasing cited increased activity in TRAFFIC newsletters, more personal sightings, and a general increase in trade on wildlife products... (Khalil et al., p. 4). This survey-based research has been submitted for publication and is expected to be published in 2017. 24 African Crafts Market, African Giraffe Skull, available at http://www.africancraftsmarket.com/giraffeskull.htm (last visited Jan. 6, 2017). 46